Regulation 19 Representations

Rep ID: 1 / Respondent: Gerald Rouse

Date Received: 12/6/2024

Section of the Plan: 12

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HEC2, paragraph 22

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Does not comply with Duty to Co-operate

Reasons: I attach a extract from the H4 plan

I brought this to the attention of the council because I didn't find any reference to the 2% requirement for allotments and was concerned new residents in South Bradwell/Gorleston would not have sufficient allotments.

One answer given was there was already sufficient reserve allotment land, and Potters Field land, then owned by Great Yarmouth & Gorleston Allotments Association Ltd, was given as an example of surplus allotment land available, it demand increased for allotments.

GYGAA Ltd recently sold this land to the James Paget Hospital, so this argument no longer stands.

A reply from GYBC Sam Hubbard replying to my concerns did not even mention allotments and I also notice that GYBC do not mention allotments in their local plan, almost ignoring the historic nature of allotments, and putting them in the same folder as any other business venture rather than an essential community need.

GYBC clear that the 2% commitment to allotment land ... approx 1 allotment per 50 new build houses, should be a priority and not ignored.

Suggested Modifications: Take account of the H4 commitment to provide allotment land in relation to the number of new builds in south Bradwell/Gorleston

Request to be heard?: Yes

Reason for Request to be heard:so I can challenge if necessary

Attachments: N/A

Rep ID: 2 / Respondent: Alan Field

Date Received: 12/11/2024

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB21

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Does not comply with Duty to Co-operate

Reasons: The current application 06/24/ 0752/ESN to consider need for EIA screening opinion is still shown as not decided on Great Yarmouth council website.

The draft local plan is predicting the outcome of the decision, bringing the planning procedures and processes into disrepute.

A previous planning application for this site was withdrawn by Norfolk County Council after objections to the planning application were were received from neighbours and government agencies such as National Highways, Anglian water, etc due to impact of traffic to and from the site on Links Road and the A47 roundabout, plus water, sewerage and drainage concerns.

The Draft Local Plan is ignoring these legitimate concerns and objections.

Suggested Modifications: The draft local plan should heed the concerns and objections of the residents and government authorities concerned.

If drainage, sewerage, water supply and the traffic impact on Links Road and the A47 roundabout cannot be overcome, the plan for housing on this site should be withdraw.

The draft local plan should not be finalised until the planning application has been decided.

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments: N/A

Rep ID: 3 / Respondent: Ian Smallwood

Date Received: 12/12/2024

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB21

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Does not comply with Duty to Co-operate

Reasons: The original withdrawn application 06/21/0213/O was to build 240 dwellings and a 60 retirement unit on high grade agricultural land ( not brown site), yet the new proposal has been increased the capacity to 600 dwellings ( 540 homes, 60 retirement units ) a dramatic increase in density and destroying green belt land.

The removal of the planned supermarket off site across the way opposite Beacon industrial area did at first reduce people's concern about the amount of traffic accessing off Links Road, however this is now being offset by increasing the number of planned dwellings entering the two access points. If every dwelling of the 540 has two cars that will mean in the region of 1100 vehicles trying to exit or turn into the site, when include deliveries. There is no mention of widening the Links Road opposite the two access points for access, furthermore Links Road has constantly got parked cars outside the existing facing dwellings, many of whom are visiting Paget Hospital thus avoiding their overflowing car parks.

Is it intended to make Links Road a restricted highway, so many of the above parked cars will move across and there is no mention of extending the bus service, which currently turns off into the Compass Estate or provision along the A47 stretch ( the east carriage way would be fine going south if a new bus layby was included, but difficult for people wanting to cross going north as the nearest pedestrian crossing is at the roundabout and nearest bus stop situated at the hospital?

No mention is made of a northern and eastern peripheral boundary separating the existing dwellings surround the site, which implies the new dwelling gardens would be backing onto these properties, here we suggest a wooded fringe would be appropriate.

Although the proposal is to provide a community center and health care facilities alongside the supermarket some distance away, there isn't anything about there being sufficient healthcare ( doctors, dentist) in the immediate vicinity which will be big enough to accommodate existing households nearby, new incumbents and retirees. My doctor is situated at Millwood Surgery 3 miles away and you need a car to get there having originally gone to the Falkland building which no longer provides GP services. Most other doctors are located in the town centre.

The proposed park land and recreation area ( I assume is intended for all to use ), being located furthest point away from the proposed access points which means locals and visitors from further a field (who drive ) have to travel further across the site, plus there is no mention of parking facility.

Suggested Modifications: See above for observations and considerations

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments: N/A

Rep ID: 4 / Respondent: John Plaskett

Date Received: 12/19/2024

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB21

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Does not comply with Duty to Co-operate

Reasons: A previous planning application was withdrawn due to concerns about traffic flow and potential congestion.

This new plan is for even more homes, 600 in total, which will lead to greater traffic movements onto Links road. Potentially over 1200 additional movements assuming 2 cars per household.

Links Road is a small road and was not built for this level of additional traffic. The road already suffers from greater traffic density with the new houses on Beaufort way and is a popular road used to access Marine Parade and the beach from right across the community.

Only having access onto Links Road for 600 properties is way above what used to be planning rules. There already exists a development on Mariners Compass of 330 homes and this has 2 separate access points, namely Links Road and Kennedy Avenue.

You have already commented that direct access onto the A47 is not under consideration but this is essential for a development of this size, or you should drastically reduce the size of this development.

Please remember that this proposed development is close to the roundabout on the A47 which is a key artery between Lowestoft and Great Yarmouth as well as leading to the James Paget hospital and the A143. Congestion on this roundabout already exists but will become many times worse with the scale of this development.

This development is in Hopton and not Gorleston and is not supported by our Parish Council. A proposed Neighbourhood plan for Hopton

does not envisage a development on this site.

The Council needs to take note of residents who elect the council and not just follow the dictate of the Westminster Government who want to build at all costs without consideration of local views. I already have over 200 residents who totally reject this proposal.

Supporting Text

4.205 You state that the development will sustainably extend the settlement of Gorleston but you forget this land is situated in Hopton.

4.206 You state that this site has good access to existing facilities. This is not true as, in addition to the continuing development along Beaufort Way, there are serious concerns regarding Doctors, Dentists, and delays at the Hospital.

4.209 It is unlikely that this level of development will be sympathetic to the neighbourhood, which is predominantly detached 3 to 5 bedroom houses and bungalows.

4.212 again, you talk about maintaining a clear gap between Gorleston and Hopton but this land sits in Hopton and will clearly join with Gorleston.

4.214 You mention that there will be no direct access onto the A47, but this is a must for a development of this size. The answer therefore, is to drastically reduce the scale of this proposal.

Suggested Modifications: The scale of this development will cause major traffic delays and is not welcomed by local residents as it is not in keeping with the local area.

The Council should instead sell off this land into individual larger building plots, between 40 and 50, and this would net NCC in excess of "£10 million with the only cost being the building of an access road.

This would enable GYBC residents to move up the housing ladder and result in smaller houses being available to purchase.

Request to be heard?: Yes

Reason for Request to be heard:Because this development is too large and does not meet residents needs and will cause major traffic congestion.

I am concerned that the council will not listen to local residents and will simply follow Government dictates.

Attachments: N/A

Rep ID: 5 / Respondent: Peter Graham

Date Received: 1/6/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Flood Risk Sequential Test Report for Great Yarmouth Local Plan Policy URB21 " Land at Links Road, Gorleston (HELAA Site ref. S142) Residential allocation of up to 600 homes Greenfield, agricultural Pockets of high, medium and low risk surface water flooding. N Development will be avoided in area of flood

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Complies with Duty to Co-operate

Reasons: The flood risk is at best ambiguous, what does "Development will be avoided in area of flood risk" , the land off Links road is significantly higher than that on the Fairway, the flood risk is to properties that site below this proposed development, as the field gets developed, rain fall will have to go somewhere? Not in my property please. Are you able to point out what the areas are that are at Flood Risk, the current outline plan does not show this.

Suggested Modifications: The land will need to be lowered to match existing levels in surrounding area.

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments: N/A

Rep ID: 6 / Respondent: Broads Authority

Date Received: 1/10/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy RUR2

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: We welcome the wording in these policies:

RUR6 Equestrian development: the scale of development is appropriate to the setting of the area, particularly where the setting of the Broads is relevant;
TCL2 New Tourist Accommodation: reflect the character of the landscape and local rural setting, including, where relevant, the setting of the Broads, being well-screened to protect the sensitive setting of the landscape.
TCL3 New Tourist Attractions outside of Development Limits and existing tourist areas: are sympathetic to the surrounding landscape, including the setting of the Broads;
CLC4 Renewable and Low-Carbon Energy Development: The character and sensitivity of the surrounding landscape, including the setting of the Broads, and designated landscape features
However, we request such wording is included in these policies as well;
RUR2 Self-Build Residential Development in the Countryside - this policy will allow small scale residential development outside of development limits which could impact on the Broads and its setting.

Soundness test

Effective - the impact of development on the Broads and its setting, which is of equivalent status to a National Park, is a cross-boundary issue.

It should be noted that the Levelling Up and Regeneration Act, which received Royal Assent on 26 October 2023, amended Section 17A of the Norfolk and Suffolk Broads Act 1988. Section 17A which creates a general duty of public bodies, and this was amended to replace "shall have regard to" with "must seek to further" as follows:

(1) In exercising or performing any functions in relation to, or so as to affect, land in the Broads, a relevant authority must seek to further the purposes of

(a) conserving and enhancing the natural beauty, wildlife and cultural heritage of the Broads;

(b) promoting opportunities for the understanding and enjoyment of the special qualities of the Broads by the public; and ] 2

The special qualities are listed here in the Broads Plan: https://www.broads-authority.gov.uk/about-us/how-we-work/strategy/broads-plan-2022/introduction

Suggested Modifications: How these concerns can be addressed:

- RUR2 Self-Build Residential Development in the Countryside: a new criterion that says: proposals are sited and designed to minimise any unacceptable impact on the character and sensitivity of the surrounding landscape, including the setting of the Broads, and designated landscape features,

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments: N/A

Rep ID: 7 / Respondent: Broads Authority

Date Received: 1/10/2025

Section of the Plan: 11

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy TCL1

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: We welcome the wording in these policies:

RUR6 Equestrian development: the scale of development is appropriate to the setting of the area, particularly where the setting of the Broads is relevant;

TCL2 New Tourist Accommodation: reflect the character of the landscape and local rural setting, including, where relevant, the setting of the Broads, being well-screened to protect the sensitive setting of the landscape.

TCL3 New Tourist Attractions outside of Development Limits and existing tourist areas: are sympathetic to the surrounding landscape, including the setting of the Broads;

CLC4 Renewable and Low-Carbon Energy Development: The character and sensitivity of the surrounding landscape, including the setting of the Broads, and designated landscape features

However, we request such wording is included in these policies as well;

TCL1 Existing Holiday Parks - some of these are up to the boundary of the Broads and changes could impact on the setting of the Broads.

Soundness test

Effective - the impact of development on the Broads and its setting, which is of equivalent status to a National Park, is a cross-boundary issue.

(1) In exercising or performing any functions in relation to, or so as to affect, land in the Broads, a relevant authority must seek to further the purposes of

(a) conserving and enhancing the natural beauty, wildlife and cultural heritage of the Broads;

(b) promoting opportunities for the understanding and enjoyment of the special qualities of the Broads by the public; and ] 2

The special qualities are listed here in the Broads Plan: https://www.broads-authority.gov.uk/about-us/how-we-work/strategy/broads-plan-2022/introduction

Suggested Modifications: add another paragraph under the bulleted criteria that says "Proposals will be designed to be appropriate to the setting of the area, particularly where the setting of the Broads is relevant"

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments: N/A

Rep ID: 8 / Respondent: Theatres Trust Tom Clarke MRTPI

Date Received: 1/13/2025

Section of the Plan: 11

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy TCL5

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: We continue to welcome and support this policy and the strength it affords to protecting Great Yarmouth's valued facilities including its theatres from unnecessary loss. We also welcome that following our previous representation the Hippodrome has now been added to the list of facilities considered strategic.

Suggested Modifications: None

Request to be heard?: Not Specified

Reason for Request to be heard:N/A

Attachments: N/A

Rep ID: 9 / Respondent: Broads Authority

Date Received: 1/10/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy RUR3

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: We welcome the wording in these policies:

RUR6 Equestrian development: the scale of development is appropriate to the setting of the area, particularly where the setting of the Broads is relevant;
TCL2 New Tourist Accommodation: reflect the character of the landscape and local rural setting, including, where relevant, the setting of the Broads, being well-screened to protect the sensitive setting of the landscape.
TCL3 New Tourist Attractions outside of Development Limits and existing tourist areas: are sympathetic to the surrounding landscape, including the setting of the Broads;
CLC4 Renewable and Low-Carbon Energy Development: The character and sensitivity of the surrounding landscape, including the setting of the Broads, and designated landscape features

However, we request such wording is included in these policies as well;

RUR2 Self-Build Residential Development in the Countryside - this policy will allow small scale residential development outside of development limits which could impact on the Broads and its setting.

Soundness test

Effective - the impact of development on the Broads and its setting, which is of equivalent status to a National Park, is a cross-boundary issue.

(1) In exercising or performing any functions in relation to, or so as to affect, land in the Broads, a relevant authority must seek to further the purposes of

(a) conserving and enhancing the natural beauty, wildlife and cultural heritage of the Broads;

(b) promoting opportunities for the understanding and enjoyment of the special qualities of the Broads by the public; and ] 2

The special qualities are listed here in the Broads Plan: https://www.broads-authority.gov.uk/about-us/how-we-work/strategy/broads-plan-2022/introduction

Suggested Modifications: How these concerns can be addressed:

RUR3 Conversion of rural buildings to residential uses: a new criterion that says: Proposals will be designed to be appropriate to the setting of the area, particularly where the setting of the Broads is relevant

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments: N/A

Rep ID: 10 / Respondent: Broads Authority

Date Received: 1/10/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy RUR4

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: We welcome the wording in these policies:

RUR6 Equestrian development: the scale of development is appropriate to the setting of the area, particularly where the setting of the Broads is relevant;
TCL2 New Tourist Accommodation: reflect the character of the landscape and local rural setting, including, where relevant, the setting of the Broads, being well-screened to protect the sensitive setting of the landscape.
TCL3 New Tourist Attractions outside of Development Limits and existing tourist areas: are sympathetic to the surrounding landscape, including the setting of the Broads;
CLC4 Renewable and Low-Carbon Energy Development: The character and sensitivity of the surrounding landscape, including the setting of the Broads, and designated landscape features;
However, we request such wording is included in these policies as well;
RUR3 Conversion of rural buildings to residential uses - this policy will allow small scale residential development outside of development limits which could impact on the Broads and its setting.

Soundness test

Effective - the impact of development on the Broads and its setting, which is of equivalent status to a National Park, is a cross-boundary issue.

(1) In exercising or performing any functions in relation to, or so as to affect, land in the Broads, a relevant authority must seek to further the purposes of

(a) conserving and enhancing the natural beauty, wildlife and cultural heritage of the Broads;

(b) promoting opportunities for the understanding and enjoyment of the special qualities of the Broads by the public; and ] 2

The special qualities are listed here in the Broads Plan: https://www.broads-authority.gov.uk/about-us/how-we-work/strategy/broads-plan-2022/introduction

Suggested Modifications: How these concerns can be addressed:

RUR4 Rural worker dwellings: a new part f that says "are sympathetic to the surrounding landscape, including the setting of the Broads"

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments: N/A

Rep ID: 11 / Respondent: Broads Authority

Date Received: 1/10/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy RUR5

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: We welcome the wording in these policies:

RUR6 Equestrian development: the scale of development is appropriate to the setting of the area, particularly where the setting of the Broads is relevant;
TCL2 New Tourist Accommodation: reflect the character of the landscape and local rural setting, including, where relevant, the setting of the Broads, being well-screened to protect the sensitive setting of the landscape.
TCL3 New Tourist Attractions outside of Development Limits and existing tourist areas: are sympathetic to the surrounding landscape, including the setting of the Broads;
CLC4 Renewable and Low-Carbon Energy Development: The character and sensitivity of the surrounding landscape, including the setting of the Broads, and designated landscape features

However, we request such wording is included in these policies as well;

RUR4 Rural worker dwellings " this policy will allow dwellings outside of development boundaries and away from built up areas, like TCL3. So similar wording to TCL3 relating to setting of the Broads is required.

Soundness test

Effective - the impact of development on the Broads and its setting, which is of equivalent status to a National Park, is a cross-boundary issue.

(1) In exercising or performing any functions in relation to, or so as to affect, land in the Broads, a relevant authority must seek to further the purposes of

(a) conserving and enhancing the natural beauty, wildlife and cultural heritage of the Broads;

(b) promoting opportunities for the understanding and enjoyment of the special qualities of the Broads by the public; and ] 2

The special qualities are listed here in the Broads Plan: https://www.broads-authority.gov.uk/about-us/how-we-work/strategy/broads-plan-2022/introduction

Suggested Modifications: How these concerns can be addressed:

- RUR5 Farm Diversification: h could be expanded to say "the scale and nature of the development is not intrusive to the surrounding landscape and are sympathetic to the surrounding landscape, including the setting of the Broads"

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments: N/A

Rep ID: 12 / Respondent: Broads Authority

Date Received: 1/10/2025

Section of the Plan: 7

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HOU3

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: We welcome the wording in these policies:

RUR6 Equestrian development: the scale of development is appropriate to the setting of the area, particularly where the setting of the Broads is relevant;
TCL2 New Tourist Accommodation: reflect the character of the landscape and local rural setting, including, where relevant, the setting of the Broads, being well-screened to protect the sensitive setting of the landscape.
TCL3 New Tourist Attractions outside of Development Limits and existing tourist areas: are sympathetic to the surrounding landscape, including the setting of the Broads;
CLC4 Renewable and Low-Carbon Energy Development: The character and sensitivity of the surrounding landscape, including the setting of the Broads, and designated landscape features

However, we request such wording is included in these policies as well;

RUR5 Farm Diversification - this policy could allow new development in rural areas, away from built up areas like TCL3. So similar wording to TCL3 relating to setting of the Broads is required.

Soundness test

Effective - the impact of development on the Broads and its setting, which is of equivalent status to a National Park, is a cross-boundary issue.

(1) In exercising or performing any functions in relation to, or so as to affect, land in the Broads, a relevant authority must seek to further the purposes of

(a) conserving and enhancing the natural beauty, wildlife and cultural heritage of the Broads;

(b) promoting opportunities for the understanding and enjoyment of the special qualities of the Broads by the public; and ] 2

The special qualities are listed here in the Broads Plan: https://www.broads-authority.gov.uk/about-us/how-we-work/strategy/broads-plan-2022/introduction

Suggested Modifications: Amend this paragraph of the policy: "All exception site proposals must demonstrate that the scheme's impact on the surrounding landscape and character, visual impact, overall footprint and intensity of the use is appropriate to the setting of the area, particularly where the setting of the Broads is relevant and is considered proportionate to the existing settlement"

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments: N/A

Rep ID: 13 / Respondent: Broads Authority

Date Received: 1/10/2025

Section of the Plan: 7

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HOU5

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: We welcome the wording in these policies:

RUR6 Equestrian development: the scale of development is appropriate to the setting of the area, particularly where the setting of the Broads is relevant;
TCL2 New Tourist Accommodation: reflect the character of the landscape and local rural setting, including, where relevant, the setting of the Broads, being well-screened to protect the sensitive setting of the landscape.
TCL3 New Tourist Attractions outside of Development Limits and existing tourist areas: are sympathetic to the surrounding landscape, including the setting of the Broads;
CLC4 Renewable and Low-Carbon Energy Development: The character and sensitivity of the surrounding landscape, including the setting of the Broads, and designated landscape features

However, we request such wording is included in these policies as well;

HOU3 Affordable Housing Exception Site - this policy will allow residential development outside of development limits which could impact on the Broads and its setting.

Soundness test

Effective - the impact of development on the Broads and its setting, which is of equivalent status to a National Park, is a cross-boundary issue.

(1) In exercising or performing any functions in relation to, or so as to affect, land in the Broads, a relevant authority must seek to further the purposes of

(a) conserving and enhancing the natural beauty, wildlife and cultural heritage of the Broads;

(b) promoting opportunities for the understanding and enjoyment of the special qualities of the Broads by the public; and ] 2

The special qualities are listed here in the Broads Plan: https://www.broads-authority.gov.uk/about-us/how-we-work/strategy/broads-plan-2022/introduction

Suggested Modifications: Amend i) as follows: "It is of a scale, height and design that appropriately accommodates its relationship to surrounding land uses and landscape, including the setting of the Broads, particularly where located at edges of settlements"

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments: N/A

Rep ID: 14 / Respondent: Broads Authority

Date Received: 1/10/2025

Section of the Plan: 9

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy EMP1

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: We welcome the wording in these policies:

RUR6 Equestrian development: the scale of development is appropriate to the setting of the area, particularly where the setting of the Broads is relevant;
TCL2 New Tourist Accommodation: reflect the character of the landscape and local rural setting, including, where relevant, the setting of the Broads, being well-screened to protect the sensitive setting of the landscape.
TCL3 New Tourist Attractions outside of Development Limits and existing tourist areas: are sympathetic to the surrounding landscape, including the setting of the Broads;
CLC4 Renewable and Low-Carbon Energy Development: The character and sensitivity of the surrounding landscape, including the setting of the Broads, and designated landscape features

However, we request such wording is included in these policies as well;

HOU5 Housing for Older People "this policy will allow residential development outside of development limits which could impact on the Broads and its setting.

Soundness test

Effective - the impact of development on the Broads and its setting, which is of equivalent status to a National Park, is a cross-boundary issue.

(1) In exercising or performing any functions in relation to, or so as to affect, land in the Broads, a relevant authority must seek to further the purposes of

(a) conserving and enhancing the natural beauty, wildlife and cultural heritage of the Broads;

(b) promoting opportunities for the understanding and enjoyment of the special qualities of the Broads by the public; and ] 2

The special qualities are listed here in the Broads Plan: https://www.broads-authority.gov.uk/about-us/how-we-work/strategy/broads-plan-2022/introduction

Suggested Modifications: How these concerns can be addressed: EMP1 New employment development: amend b) as follows: 'its scale is rural in character and sensitive to surroundings, including the setting of the Broads, and well-related to existing settlements';

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments: N/A

Rep ID: 15 / Respondent: Broads Authority

Date Received: 1/10/2025

Section of the Plan: 9

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy EMP2

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: We welcome the wording in these policies:

RUR6 Equestrian development: the scale of development is appropriate to the setting of the area, particularly where the setting of the Broads is relevant;

TCL3 New Tourist Attractions outside of Development Limits and existing tourist areas: are sympathetic to the surrounding landscape, including the setting of the Broads;

CLC4 Renewable and Low-Carbon Energy Development: The character and sensitivity of the surrounding landscape, including the setting of the Broads, and designated landscape features

However, we request such wording is included in these policies as well;

EMP1 New employment development "this policy could allow employment uses outside of development limits which could impact on the Broads and its setting.

Soundness test

Effective - the impact of development on the Broads and its setting, which is of equivalent status to a National Park, is a cross-boundary issue.

(1) In exercising or performing any functions in relation to, or so as to affect, land in the Broads, a relevant authority must seek to further the purposes of

(a) conserving and enhancing the natural beauty, wildlife and cultural heritage of the Broads;

(b) promoting opportunities for the understanding and enjoyment of the special qualities of the Broads by the public; and ] 2

The special qualities are listed here in the Broads Plan: https://www.broads-authority.gov.uk/about-us/how-we-work/strategy/broads-plan-2022/introduction

Suggested Modifications: How these concerns can be addressed: EMP2 Protected Employment Sites: add a new criterion that says: Proposals will be designed to be appropriate to the setting of the area, particularly where the setting of the Broads is relevant

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments: N/A

Rep ID: 16 / Respondent: Broads Authority

Date Received: 1/10/2025

Section of the Plan: 9

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy EMP3

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: We welcome the wording in these policies:

RUR6 Equestrian development: the scale of development is appropriate to the setting of the area, particularly where the setting of the Broads is relevant;
TCL2 New Tourist Accommodation: reflect the character of the landscape and local rural setting, including, where relevant, the setting of the Broads, being well-screened to protect the sensitive setting of the landscape.
TCL3 New Tourist Attractions outside of Development Limits and existing tourist areas: are sympathetic to the surrounding landscape, including the setting of the Broads;
CLC4 Renewable and Low-Carbon Energy Development: The character and sensitivity of the surrounding landscape, including the setting of the Broads, and designated landscape features

However, we request such wording is included in these policies as well;

EMP2 Protected Employment Sites " some of these sites are near to or next to the Broads and development could impact on the Broads and its setting.

Soundness test

Effective - the impact of development on the Broads and its setting, which is of equivalent status to a National Park, is a cross-boundary issue.

(1) In exercising or performing any functions in relation to, or so as to affect, land in the Broads, a relevant authority must seek to further the purposes of

(a) conserving and enhancing the natural beauty, wildlife and cultural heritage of the Broads;

(b) promoting opportunities for the understanding and enjoyment of the special qualities of the Broads by the public; and ] 2

The special qualities are listed here in the Broads Plan: https://www.broads-authority.gov.uk/about-us/how-we-work/strategy/broads-plan-2022/introduction

Suggested Modifications: How these concerns can be addressed: EMP3 Digital Infrastructure: amend a) as follows: "The installation and any associated apparatus is sited and designed to minimise any unacceptable impact on visual and residential amenity, highway safety, the historic environment, and the appearance of the area where it would be sited and the character and sensitivity of the immediate and surrounding landscape, including the setting of the Broads, and designated landscape features, including through the use of innovative design and construction and/or sympathetic camouflaging and landscaping"

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments: N/A

Rep ID: 17 / Respondent: Broads Authority

Date Received: 1/10/2025

Section of the Plan: 12

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HEC4

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: We welcome the wording in these policies:

RUR6 Equestrian development: the scale of development is appropriate to the setting of the area, particularly where the setting of the Broads is relevant;
TCL2 New Tourist Accommodation: reflect the character of the landscape and local rural setting, including, where relevant, the setting of the Broads, being well-screened to protect the sensitive setting of the landscape.
TCL3 New Tourist Attractions outside of Development Limits and existing tourist areas: are sympathetic to the surrounding landscape, including the setting of the Broads;
CLC4 Renewable and Low-Carbon Energy Development: The character and sensitivity of the surrounding landscape, including the setting of the Broads, and designated landscape features

However, we request such wording is included in these policies as well;

EMP3 Digital Infrastructure " this policy will allow telecommunications infrastructure to be built. Such infrastructure could affect the Broads and its setting. So again, similar wording to TCL3 is required and consideration of the Broads LCA.

Soundness test

Effective " the impact of development on the Broads and its setting, which is of equivalent status to a National Park, is a cross-boundary issue.

(1) In exercising or performing any functions in relation to, or so as to affect, land in the Broads, a relevant authority must seek to further the purposes of

(a) conserving and enhancing the natural beauty, wildlife and cultural heritage of the Broads;

(b) promoting opportunities for the understanding and enjoyment of the special qualities of the Broads by the public; and ] 2

The special qualities are listed here in the Broads Plan: https://www.broads-authority.gov.uk/about-us/how-we-work/strategy/broads-plan-2022/introduction

Suggested Modifications: How these concerns can be addressed: HEC4 Community Facilities; amend first paragraph of policy: "Proposals for new community services and facilities will be permitted within and outside of Development Limits, if the proposal meets the needs of the local community, is of a proportionate scale, is well related to the settlement which it will serve and would not adversely affect existing facilities that are more easily accessible and available to the local community. Proposals will be designed to be appropriate to the setting of the area, particularly where the setting of the Broads is relevant"

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments: N/A

Rep ID: 18 / Respondent: Broads Authority

Date Received: 1/10/2025

Section of the Plan: 15

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy DHE6

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: We welcome the wording in these policies:

RUR6 Equestrian development: the scale of development is appropriate to the setting of the area, particularly where the setting of the Broads is relevant;
TCL2 New Tourist Accommodation: reflect the character of the landscape and local rural setting, including, where relevant, the setting of the Broads, being well-screened to protect the sensitive setting of the landscape.
TCL3 New Tourist Attractions outside of Development Limits and existing tourist areas: are sympathetic to the surrounding landscape, including the setting of the Broads;
CLC4 Renewable and Low-Carbon Energy Development: The character and sensitivity of the surrounding landscape, including the setting of the Broads, and designated landscape features

However, we request such wording is included in these policies as well;

DHE6 Advertisements " some signs could be illuminated, or their design could impact on the landscape.

Soundness test

Effective - "the impact of development on the Broads and its setting, which is of equivalent status to a National Park, is a cross-boundary issue.

(1) In exercising or performing any functions in relation to, or so as to affect, land in the Broads, a relevant authority must seek to further the purposes of

(a) conserving and enhancing the natural beauty, wildlife and cultural heritage of the Broads;

(b) promoting opportunities for the understanding and enjoyment of the special qualities of the Broads by the public; and ] 2

The special qualities are listed here in the Broads Plan: https://www.broads-authority.gov.uk/about-us/how-we-work/strategy/broads-plan-2022/introduction

Suggested Modifications: How these concerns can be addressed:

DHE6 Advertisements: amend first part of the policy as follows: "In assessing advertisement proposals in terms of amenity, regard will be given to the local characteristics of the area in terms of potential impact on the scenic, historic, architectural, landscape or cultural setting, and whether it is in scale and in keeping with these features, including protected landscapes and their setting"

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments: N/A

Rep ID: 19 / Respondent: Broads Authority

Date Received: 1/10/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Burgh Castle

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Burgh Castle policies - soundness objection

The supporting text highlights the need for a sensitive design approach in relation to the Broads area to the north and west, with mention of unsuitable boundary treatments and the need for screening. I am pleased to see that a landscape strategy would be required in accordance with the site-specific policy. There is however no mention of the potential need to assess the visibility of the site, and the landscape strategy should be informed by a landscape and visual appraisal. This would be necessary to inform potential building heights and limit them if necessary, on the more sensitive areas of the site. This would also be an opportunity to identify and mitigate any visibility from the sensitive Burgh Castle ruins site.

Soundness test

Effective "the impact of development on the Broads and its setting, which is of equivalent status to a National Park, is a cross-boundary issue.

(1) In exercising or performing any functions in relation to, or so as to affect, land in the Broads, a relevant authority must seek to further the purposes of

(a) conserving and enhancing the natural beauty, wildlife and cultural heritage of the Broads;

(b) promoting opportunities for the understanding and enjoyment of the special qualities of the Broads by the public; and ] 2

The special qualities are listed here in the Broads Plan: https://www.broads-authority.gov.uk/about-us/how-we-work/strategy/broads-plan-2022/introduction

Suggested Modifications: Amend policies to refer to the need to assess the visibility of the site, and the landscape strategy should be informed by a landscape and visual appraisal.

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments: N/A

Rep ID: 20 / Respondent: Broads Authority

Date Received: 1/10/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Martham Policies

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: The need for a sensitive design approach is highlighted, and a landscape strategy is required which provides retention of existing valuable features and inclusion of new screening. However, there is no mention of any landscape and visual appraisal informing this landscape strategy. This would be the only way of determining important views towards and potentially out of the site to help inform which parts of these site have more capacity to accommodate greater height etc and which might need to be kept more open. This would also help inform where the open spaces would be best located.

Soundness test

Effective - the impact of development on the Broads and its setting, which is of equivalent status to a National Park, is a cross-boundary issue.

(1) In exercising or performing any functions in relation to, or so as to affect, land in the Broads, a relevant authority must seek to further the purposes of

(a) conserving and enhancing the natural beauty, wildlife and cultural heritage of the Broads;

(b) promoting opportunities for the understanding and enjoyment of the special qualities of the Broads by the public; and ] 2

The special qualities are listed here in the Broads Plan: https://www.broads-authority.gov.uk/about-us/how-we-work/strategy/broads-plan-2022/introduction

Suggested Modifications: Refer to the need for any landscape and visual appraisal informing this landscape strategy.

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments: N/A

Rep ID: 21 / Respondent: Broads Authority

Date Received: 1/10/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy FLG1

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: There is no way of determining how visible the site is from the Broads without a suitable appraisal being carried out, which should inform appropriate measures to either screen or transition from the settlement edge to rural countryside.

Soundness test

Effective - the impact of development on the Broads and its setting, which is of equivalent status to a National Park, is a cross-boundary issue.

(1) In exercising or performing any functions in relation to, or so as to affect, land in the Broads, a relevant authority must seek to further the purposes of

(a) conserving and enhancing the natural beauty, wildlife and cultural heritage of the Broads;

(b) promoting opportunities for the understanding and enjoyment of the special qualities of the Broads by the public; and ] 2

The special qualities are listed here in the Broads Plan: https://www.broads-authority.gov.uk/about-us/how-we-work/strategy/broads-plan-2022/introduction

Suggested Modifications: Refer to the need for a Landscape and Visual Impact Assessment.

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments: N/A

Rep ID: 22 / Respondent: Theatres Trust Tom Clarke MRTPI

Date Received: 1/13/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB14

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: We remain supportive of this policy and its framework for the positive re-use of important cultural and heritage assets within the area including the vacant former Regent Theatre.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:N/A

Attachments: N/A

Rep ID: 23 / Respondent: Theatres Trust Tom Clarke MRTPI

Date Received: 1/13/2025

Section of the Plan: 0

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Appendix 2 Marketing Requirements

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Following our previous representation we welcome that some reference is now made to specialist publications including both local and national publications.

Suggested Modifications: None

Request to be heard?: Not Specified

Reason for Request to be heard:N/A

Attachments: N/A

Rep ID: 24 / Respondent: Broads Society Sarah Vergette

Date Received: 12/17/2024

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT6

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: The Broads Society broadly welcomes the Local Plan and specifically supports policies NAT6, NAT7 and NAT9 which should ensure that the integrity and amenity of the adjoining Broads area is protected.'

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:N/A

Attachments: N/A

Rep ID: 25 / Respondent: Broads Society Sarah Vergette

Date Received: 12/17/2024

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT7

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:N/A

Attachments: N/A

Date Received: 12/17/2024

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB19

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP 27-45 - Water Management Alliance (PDF, 210 KB)(opens new window)

Rep ID: 31 / Respondent: Water Management Alliance

Date Received: 12/17/2024

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB20

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Major employment development. Whilst outside the Board's IDD, the Board would comment to promote sustainable drainage as any runoff will enter the Board's district indirectly. Consent may be required if a discharge is proposed directly within the IDD.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP 27-45 - Water Management Alliance (PDF, 210 KB)(opens new window)

Rep ID: 32 / Respondent: Water Management Alliance

Date Received: 12/17/2024

Section of the Plan: 5

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CAS1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP 27-45 - Water Management Alliance (PDF, 210 KB)(opens new window)

Rep ID: 33 / Respondent: Water Management Alliance

Date Received: 12/17/2024

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy BEL1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP 27-45 - Water Management Alliance (PDF, 210 KB)(opens new window)

Rep ID: 34 / Respondent: Water Management Alliance

Date Received: 12/17/2024

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy BUR1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP 27-45 - Water Management Alliance (PDF, 210 KB)(opens new window)

Rep ID: 35 / Respondent: Water Management Alliance

Date Received: 12/17/2024

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy FLG1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP 27-45 - Water Management Alliance (PDF, 210 KB)(opens new window)

Rep ID: 36 / Respondent: Water Management Alliance

Date Received: 12/17/2024

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HEM1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Suggested Modifications: None

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP 27-45 - Water Management Alliance (PDF, 210 KB)(opens new window)

Rep ID: 37 / Respondent: Water Management Alliance

Date Received: 12/17/2024

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy ORM1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Suggested Modifications: None

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP 27-45 - Water Management Alliance (PDF, 210 KB)(opens new window)

Rep ID: 38 / Respondent: Water Management Alliance

Date Received: 12/17/2024

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy ORM2

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Suggested Modifications: None

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP 27-45 - Water Management Alliance (PDF, 210 KB)(opens new window)

Rep ID: 39 / Respondent: Water Management Alliance

Date Received: 12/17/2024

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy ORM3

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Suggested Modifications: None

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP 27-45 - Water Management Alliance (PDF, 210 KB)(opens new window)

Rep ID: 40 / Respondent: Water Management Alliance

Date Received: 12/17/2024

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy MAR1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP 27-45 - Water Management Alliance (PDF, 210 KB)(opens new window)

Rep ID: 41 / Respondent: Water Management Alliance

Date Received: 12/17/2024

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy MAR2

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP 27-45 - Water Management Alliance (PDF, 210 KB)(opens new window)

Rep ID: 42 / Respondent: Water Management Alliance

Date Received: 12/17/2024

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy MAR3

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP 27-45 - Water Management Alliance (PDF, 210 KB)

Rep ID: 43 / Respondent: Water Management Alliance

Date Received: 12/17/2024

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy MAR4

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP 27-45 - Water Management Alliance (PDF, 210 KB)

Rep ID: 44 / Respondent: Water Management Alliance

Date Received: 12/17/2024

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy MAR6

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP 27-45 - Water Management Alliance (PDF, 210 KB)

Rep ID: 45 / Respondent: Water Management Alliance

Date Received: 12/17/2024

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy REP1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Suggested Modifications: None

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP 27-45 - Water Management Alliance (PDF, 210 KB)

Rep ID: 46 / Respondent: National Highways Alice Lawman

Date Received: 12/30/2024

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:-

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: National Highways has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the strategic road network (SRN). The SRN is a critical national asset and as such National Highways works to ensure that it operates and is managed in the public interest, both in respect of current activities and needs as well as in providing effective stewardship of its long-term operation and integrity.

We will therefore be concerned with proposals that have the potential to impact the safe and efficient operation of the SRN, in this case the A47. As identified within the Great Yarmouth Local Plan Infrastructure Needs Study document, it is understood that each allocation site would need to identify infrastructure improvements and how the mitigation would be secured. This includes developments requiring mitigation on the Strategic Road Network

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 47 / Respondent: Jane Jordan

Date Received: 1/12/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB21

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound

Reasons: With regard to the above development it is ridiculous to have the only access onto Links Road.

Given the massive increase of traffic from six hundred homes, care home and commercial premises there could be in excess of two to three thousand traffic movements per day. This would dramatically reduce the traffic flow which at times in the summer is bad enough.

Currently, attempting to gain access to the A47 is problematical and trying to cross to the A143 is close to suicidal as there is only room for two vehicles to wait for the traffic lights to change, anymore would obstruct the through flow of the A47.

Any increase in traffic from the Links Road Development would only exacerbate this.

Human nature being what it is, "rat runs" would form through Cliff Park Estate and along the seafront.

In conclusion, the only possible solution to avoid severe congestion would be slip roads into and out of the development via the A47.

I cannot comment on the legality, I therefore wish to register my objection to the soundness of the proposal as it stands.

Suggested Modifications: The Council consulted with Norfolk County Council and National Highways during plan preparation, and neither objected to proposed allocation URB21 based on highway impacts or safety.

The Local Plan is supported by Traffic Modelling Analysis (documents B16 and B17), which shows the road network can handle the growth identified in the plan. Although the site may impact the A47/Beaufort Way roundabout's capacity, national policy requires the impact to be 'severe' to justify prevention or refusal.

Proposed allocation URB21 and the Local Plan will not cause severe impacts on the highway network. Policy URB21 requires any planning application to include a site-specific Transport Assessment and may necessitate further mitigation measures or road network improvements. No further changes are considered necessary.

Request to be heard?: Not Specified

Date Received: 1/7/2025

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:General

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: 4. I am always concerned where Local Plans take otherwise policy (eg Building Regulations, national policy) such as energy efficient, space standards, etc as it's superfluous and not nimble enough a structure to keep upto date, lacking flexilbity.

Suggested Modifications: Proposed allocation URB21 and the Local Plan will not cause severe impacts on the highway network. Policy URB21 requires any planning application to include a site-specific Transport Assessment and may necessitate further mitigation measures or road network improvements. No further changes are considered necessary.

Request to be heard?: No

Reason for Request to be heard:I do not need to take part in hearing proceedings if the above points are taken on board in submission version; otherwise I reserve the right to please do so.

Attachments: N/A

Rep ID: 52 / Respondent: Poppyfields Terry Harper

Date Received: 1/7/2025

Section of the Plan: 15

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy DHE3

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: 5. Non designated Heritage Assets need to be recorded and listed, which otherwise are too subjective to be brought in at DC level and lack certainty (if not objectivity).

Suggested Modifications:

Request to be heard?: No

Reason for Request to be heard:I do not need to take part in hearing proceedings if the above points are taken on board in submission version; otherwise I reserve the right to please do so.

Attachments: N/A

Rep ID: 53 / Respondent: Broads Authority

Date Received: 1/10/2025

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:3.4

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: -

Suggested Modifications: 3.4 says 'Site specific policies and policies in the housing section of this plan aim to help meet these specialist needs'

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 54 / Respondent: Broads Authority

Date Received: 1/11/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:4.49

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: -

Suggested Modifications: a minor comment - could there be scope for a viewpoint towards Breydon Water from the waterfront, at the apex of the curved water frontage?

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 55 / Respondent: Broads Authority

Date Received: 1/12/2025

Section of the Plan: 8

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:8.4

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: -

Suggested Modifications: some of these sites may be immune to planning enforcement. There is work ongoing regarding this. We will keep you updated.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 56 / Respondent: Broads Authority

Date Received: 1/13/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy RUR1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: -

Suggested Modifications: on a couple of occasions in the policy, it refers to 'in accordance with the above proportion'. Not sure what the phrase in this context actually means.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 57 / Respondent: Broads Authority

Date Received: 1/14/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy RUR2

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: -

Suggested Modifications: D - the policy refers to schemes in the countryside, but D refers to a village. 6.236 then refers to rural settlements. Need to be consistent with terminology.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 58 / Respondent: Broads Authority

Date Received: 1/15/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy RUR6

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: -

Suggested Modifications: recommend mention lighting in there as often equestrian development is on the edge of settlements and often has lighting included.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 59 / Respondent: Broads Authority

Date Received: 1/16/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT7

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: -

Suggested Modifications: our LCA and LSS are being updated. They should be in place before this Local Plan is adopted - you will need to check their status so reference can be correct.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 60 / Respondent: Evolution Town Planning on behalf of Fritton Lake Resort CO Evolution Town Planning

Date Received: 1/20/2025

Section of the Plan: 0

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policies Map

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: These representations are made by Evolution Town Planning on behalf of the Somerleyton Estate who own and run the popular Fritton Lake holiday resort near to the village of Fritton. Fritton Lake provides high quality accommodation in an attractive setting. The Estates rewilding programme complements the resort which has become an important eco-tourism destination. These representations set out what should be the extent of the Fritton Lake 'Existing Holiday Park' area in the Local Plan. The representations describe two new areas of land which are needed for the expansion of Fritton Lake over the lifetime of the Local Plan. This expansion area is very important to achieving the aspirations of the resort in the coming years and will support the capital investment plan that is underway. The location of the Fritton Lake resort is shown on the plan at Appendix 1. A plan of the Fritton Lake resort is included at Appendix 2.

The Fritton Lake resort is carrying out a major investment plan which will continue over the next few years. This will increase the facilities and the year-round use of the resort. Achieving this requires a supporting Planning Policy. The recent improvements include the creation of a new swimming pool and tennis courts. In future, there is proposed to be a new adventure play area, a second restaurant/bar serving food all day near to the swimming pool, and an increase in the number of lodges.

The resort currently employs around 45 people. This has grown from 25 employees in 2020, and the investment in and expansion of the accommodation and facilities that are set out in this report will lead to further employment. Increasing employment will ensure that the resort helps the Council achieve the aim set out in the Key Issues and Opportunities part of the draft Local Plan which include addressing high unemployment rates in the Borough since 2015 and a recognition of the Borough's strong tourism industry.

The investment which is proposed will improve the year-round use of the resort. Many coastal areas experience wide seasonal variations in tourist visits between summer and winter. This means that much employment in tourist areas is seasonal and lower quality than permanent employment. Great Yarmouth is no exception. Objective 4 of the draft Local Plan is 'to improve and grow the year-round tourist offer of the Borough, including the Borough'. Investment in reducing the seasonal nature of the tourism industry is an important factor in improving the quality of employment in the industry which is of great benefit to the local economy and population. With its high-quality restaurant, lodges, lakeside walks, tennis, and heated pool, Fritton Lake is popular all year round.

By way of background to the Somerleyton Estate, the Estate is a major employer and landowner in the villages of Somerleyton and Fritton and has a close and long-term interest in the vitality of the local area. Like many Estates the owner's families and many employees have lived in the area for generations, and they see their stewardship lasting into the future. This gives them a different outlook and objective compared to developers who may be involved in an area for a short time before moving on. The current owner, Hugh Somerleyton, strongly believes that the local area needs sustainable local businesses which take a long-term view and the Estate has a long history of investing in a number of local enterprises.

For example, the Grade II* Listed Somerleyton Hall and Gardens are a major tourist attraction. The Estate owns and supports the Duke's Head pub in Somerleyton village. The Estate became involved in the Duke's Head pub when it was in danger of closing. The Estate bought the marina in Somerleyton village when it was put up for sale and is improving the facilities that are available there. There is a large agricultural operation on the Estate.

The Estate has embarked on a significant rewilding project and is now seen as an eco-tourism destination. Rewilding is a process which encourages landowners and occupiers to make changes to how they use the environment for the benefit of nature and eco systems. It is an initiative which can be engaged in at a range of scales, from domestic gardens to large estates of land, but the aim is to use land in less intensive ways so that nature can colonise and coexist with other uses, thus enabling the flourishing of wild nature on its own terms.

On the Somerleyton Estate, Hugh Somerleyton has been pioneering in raising awareness of rewilding particularly around Fritton Lake. On the Estate, rewilding includes 400 hectares of land and began in 2016. As such, it is a large-scale project, which aims to facilitate the rewilding of mixed woodland, lakes and ponds, grassland and meadow land, heathlands, and shrub habitats. Key species introduced have included ponies, cattle, and pigs. A key part of the rewilding project is enabling extensive grazing for these animals and natural regeneration. As such, the Estate has taken the decision to move away from intensive sheep grazing and traditional management to a rewilding approach, enabling extensive low-density cattle grazing instead. A reduction in sheep grazing was essential to allow natural processes more free reign on the site. More diverse, functional grazing animals were introduced to the project area to create species diversity and wood pasture habitats. In addition, the removal of non-native invasive species and fences was required.

This project is part of the wider Wild East project, aimed to promote nature recovery across the region and return 20% of land to nature. Much of the Somerleyton rewilding has taken place near to Fritton Lake.

The Fritton Lake website describes the resort as follows:

'The resort at Fritton Lake (just under 4 miles from Somerleyton Hall) is unique in East Anglia, a private holiday resort within a pioneering thousand acre re-wilding project where adventurous play, wild swimming, robust activities, and great food exist in perfect harmony with a naturalistic grazing system set up to enrich the bio-diversity around Fritton Lake and the wider Somerleyton Estate. It is part of the historic and prestigious 5,000 acre Somerleyton Estate on the Norfolk/ Suffolk border. The park itself is set within 250 acres of mature woodland and parkland and has one of the most beautiful lakes in East Anglia. The Fritton Arms is the club pub, with its own eclectic mix of accommodation and where owners and local members congregate to enjoy the hospitality'.

The Fritton Lake resort offers many activities including: open water swimming, paddle boarding, archery, tennis, shelter building, Jeep safari tours, foraging, fishing, lake awareness, various studio classes, treatments, and a gym.

Fritton Lake has around 95 lodges at present and the number is expanding as the existing planning consents are built out. The resort is popular all year and at various times of the year it is fully occupied. The investment set out above will create new jobs and will help to reduce the seasonality of the local tourism industry.

There are currently around 45 people employed at Fritton Lake. This number could increase over the next few years. This job growth is dependent on more facilities and accommodation being provided on the existing site and the expansion of the site as set out in these representations.

This demonstrates the economic importance of Fritton Lake both in bringing visitors to the area which boosts the local economy, and in providing employment for local people in an established and successful business.

The amendments that are sought to the Plan to help achieve the growth set out above include enlarging the area covered by the Holiday Park area designation. At present, the Holiday Park area designation does not cover the whole of the Fritton Lake resort or areas that the resort would like to use for expansion. The plan in Appendix 2 shows in orange the existing area identified as a Holiday Area within the draft Local Plan. The blue area is currently used as part of the resort and the Holiday Park area should be expanded to include this area. The larger blue area is part of the leisure area and currently contains walks and parking. It is contained within the landscape and is not widely visible. New facilities could be developed here and a supportive Local Plan policy is required. The larger blue area is well related to the existing holiday area and the existing facilities at Fritton Lake which are to the south and east.

The smaller blue area was recently bought by the resort. It is woodland like the surrounding land. This area is surrounded on all sides south of the road by the Holiday Park area so it should be included within the designation.

The blue shaded land is outside the Area of Outstanding Natural Beauty (AONB) and has the same landscape designations as the area already occupied by the resort. Including this land as part of the Holiday Park would allow the resort to expand its leisure activities and the accommodation that is offered to visitors. Expanding an existing successful tourist attraction is the best way to improve the local economy. Not to include the blue area within the designation will make the operation and improvement of the resort more difficult as different planning policies would apply to different parts of the same site, making improvement of the facilities difficult.

The expansion of Fritton Lake is supported by National Planning Policy in the National Planning Policy Framework December 2024 (NPPF). The NPPF seeks to deliver sustainable development. This is defined as having three roles which are: an economic role; a social role, and an environmental role. The economic role is to build a strong and competitive economy by supporting growth and innovation. The social role requires a high quality environment to be created which reflects a community's needs and supports its health, cultural, and social well-being. The environmental role is about protecting and enhancing the built and natural environment. Supporting and expanding the Fritton Lake resort will meet the economic role of sustainable development by increasing employment, reducing seasonal employment and by encouraging tourism. These are also important objectives of the Local Plan. The social role will be met by expanding a high-quality facility that provides a wide range of social and leisure activities and entertainment for tourists and local people. The environmental role will be met though delivering a high-quality development that respects the character and environmental importance of the local area. The quality of the existing development and the Estates rewilding demonstrate how this can be achieved.

The NPPF (Paragraph 85) states that the planning system should give 'significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development'. Paragraph 87 states that 'planning policies and decisions should recognise and address the specific locational requirements of different sectors'.

In Paragraph 88 The Framework states that 'planning policies and decisions should enable the sustainable growth and expansion of all types of business in rural areas'. The paragraph also provides support for 'sustainable rural tourism and leisure which respect the character of the countryside'.

The NPPF gives strong support to economic growth. It requires 'significant weight' to be given to supporting economic growth and states that Local Planning Authorities should take account of local business needs and the wider opportunities for development. Specific locational requirements of different sectors should be recognised. The NPPF states that growth of all types of businesses in rural areas should be supported, as should sustainable tourism and leisure in rural areas. The NPPF provides strong support for the growth of the Fritton Lake resort which needs support to grow its existing site and requires that the particular needs of the business are recognised in planning decisions.

Suggested Modifications: In conclusion, to be sound, the Local Plan should include an amended Holiday Park area plan on the Policies Map to include the two areas of land shaded in blue which currently forms part of the Fritton Lake resort. Without this change, the plan will not be sound. Firstly, the plan will not be justified as it will not be the most appropriate strategy. Secondly, the plan will not conform to the requirement of National Planning Policy to support economic growth. By not including this land within the Holiday Area, the Local Plan will not achieve its aim of improving and enhancing the existing tourism and leisure offer. Amending the Holiday Park area to reflect the actual area of the resort, and expanding the resort, will be important in assisting with the expansion and investment plans set out at the start of this report and will help to create good quality, local jobs.

Request to be heard?: Yes

Reason for Request to be heard:To ensure that the inspector understands our objections.

Attachments: REP60 - Fritton Lake Resort (PDF, 1 MB)(opens new window)

Rep ID: 61 / Respondent: Evolution Town Planning on behalf of Trustees 1971 Settlement Michael

Date Received: 1/20/2025

Section of the Plan: 0

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policies Map

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: These representations object to the strategy of housing allocations in the draft Local Plan. The Plan makes too few housing allocations in the villages. This does not accord with the National Planning Policy Framework December 2024 (NPPF).The NPPF encourages an approach to housing delivery in rural areas that will enhance or maintain the vitality of rural settlements. New development can support new and existing services and facilities and provide a wider choice of quality new homes where they are needed. Growth is also supported where development in one settlement can support people living in communities nearby. The Local Plan strategy should be amended so that additional land is allocated in the rural areas of the Borough. This is particularly important given the housing supply problems in the Borough. The NPPF requires that 10% of housing should be provided on sites of 1 hectare or less. The 2024 revision of the NPPF included greater emphasis on delivering small and medium sized sites. This measure has been introduced in order to help small builders and to boost housing supply. Small sites are quick and easy to develop compared to larger sites which can take several years to come forward. Allocating sites that will be developed by small, local builders helps the local economy. To address this requirement, and to realise the benefits to the economy and housing delivery that come from small sites, the Local Plan should allocate more small rural sites.Paragraph 61 of the NPPF seeks to significantly boost the supply of housing. Paragraph 82 of the NPPF states that in rural areas, Local Planning Authorities should be responsive to local circumstances and support housing development that reflects local needs. There is a need for housing across the country and across The Borough of Great Yarmouth, including in rural areas. The allocation of more rural sites in villages can help to meet this need. Paragraph 83 of the NPPF states that, to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. When allocating sites in villages, the Council can require that the sites provide housing of a type required in the local area so that they will sustain local communities. For example, this could include a requirement for bungalows for older people from the community who want to downsize and stay in villages, or for smaller homes for younger people who have grown up in the area and want to remain where they have grown up. This will ensure that the allocation of sites in villages contributes to delivering sustainable development.

Paragraph 83 of the NPPF states: 'To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this would support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby'. This paragraph recognises that new housing provides a social and economic benefit to rural areas. Villages range in size and development in more villages will support services that are valuable to sustain smaller hamlets and groups of homes.The NPPF recognises in Paragraph 73 that small and medium sized sites 'can make an important contribution to meeting the housing supply of an area, are essential for Small and Medium Enterprise housebuilders to deliver homes, and are often built-out relatively quickly'. Developing small sites can support local builders and the local economy in a way that large sites cannot. Paragraph 70 continues that Local Planning Authorities should: 'identify, through the development plan and brownfield registers, land to accommodate at least 10% of their housing requirement on sites no larger than one hectare'. The allocation of small housing sites in villages would meet this important requirement of the NPPF.Developing small sites benefits local businesses more when compared with developing large sites where labour and materials are more likely to be brought in from outside the local area. This will help the draft Local Plan to meet the requirement of Paragraph 85 of the NPPF which states: 'significant weight should be placed on the need to support economic growth and productivity, taking into account local business needs and wider opportunities for development'.

Paragraph 8 of the NPPF sets out the three dimensions of sustainable development to be considered in determining the sustainability of a housing development. It emphasizes the need for the decision maker to balance the economic, social, and environmental role of the proposals towards weighing up its overall sustainability.

The economic role seeks to ensure 'that sufficient land of the right type is available in the right places at the right time to support growth'. The social role seeks to ensure proposals contribute 'to support strong, vibrant, and healthy communities by ensuring a sufficient number and range of homes can be provided to meet the needs of present and future generations'. The environmental role seeks to ensure development contributes to 'protecting and enhancing our natural, built and historic environment'.

The allocation of sites in more villages can meet the three roles of sustainability in the following ways:

• Environmental: Sites can be sustainably located within a short distance of bus stops and facilities in villages. The principle of net ecological gain can be followed to deliver environmental enhancements.

• Social: The development will support local services and facilities such as bus services, shops, and village activities. Housing developments can provide housing to meet local needs such as homes for older people or young families depending on local circumstances.

• Economic: Occupants of new homes would support the services and facilities of the villages. There would also be additional economic benefits to the local economy brought about from by the construction.

Suggested Modifications: To be sound by being in accordance with National Planning Policy and positively prepared, the Plan should be modified to include allocations of small sites in more villages. This would ensure that the Plan meets the requirements of National Planning Policy by delivering sustainable development in rural areas and delivering small sites. Delivering homes that meet local needs is an important element of sustainable development. This would be the most justified strategy as the alternatives do not support sustainable development in rural areas or the delivery of small sites. The change will make the draft Plan Positively Prepared by delivering homes where they are needed, and on a scale that will support the local economy.

To address the need for housing in the villages we propose the allocation for housing of land south of the A143 in the village of Fritton. A plan of the site is included in Appendix 1 with the proposed allocation hatched blue. We have worked on a large number of similar sites and consider that this site would be deliverable and is well located so that it would provide a sustainable housing development of around 4-8 homes. This site is very well related to the built-up area of Fritton, with existing housing and commercial development on three sides, and the A143 as the northern boundary. The site has a 95 metre straight road frontage with the A143 within a 30mph speed limit. This road frontage is within the built-up area of the village.

The purpose of making provision for small scale housing allocations in villages like Fritton is to ensure that local services can be sustained economically and that people wishing to live in the area have the opportunity to do so. The nature of the village means that there are few opportunities for windfall development, as the historic low level of windfall development shows. Reliance on infill development in many of the villages to deliver the housing required in the Local Plan does not meet an area's housing needs. Infill development tends to result in the largest homes that can be developed on a plot, and often does not deliver the range of house types to meet local needs. Housing allocations can deliver a range of house types. If the village is left with no housing allocation there will be few, if any, opportunities during the plan period for sustainable rural housing growth, leaving villages to stagnate and the issue of the lack of availability of appropriate rural housing will not be addressed.

Development is suitable for the Fritton site. A vehicular access could be created at the western end of the A143 road frontage. An access in this location would be away from the T- junction with New Road to the east. In this location the new vehicular access would have visibility of 90 metres to the east and in excess of 90 metres to the west. This is sufficient visibility to safely construct an access in a built-up residential area. There are roadside public footways, and numerous turnings onto the road from homes. As well as side streets, a pub, and a bed and breakfast very close by, so one new access for around 10 new homes would not be difficult to construct and operate safely.

The site is owned by the Somerleyton Estate. By way of background to the Somerleyton Estate, the Estate is a major employer and landowner in the villages of Somerleyton, Lound, and Fritton and has a close and long-term interest in the vitality of the local area. The current owner, Hugh Somerleyton, strongly believes that the local area needs sustainable, long-term businesses and the Estate has a long history of investing in a number of local enterprises.

For example, Somerleyton Hall and Gardens are a major tourist attraction. The Estate owns and runs the Fritton Lake resort which provides holiday accommodation with leisure activities. Fritton lake employs around 40 local people.

Achieving developments on sites like this in Fritton is very important for the Estate. The main aims of the Estate are sustaining and conserving the Grade II * Listed Somerleyton Hall and Gardens and investing in the local businesses that it owns. This in turn sustains local jobs and the local tourist economy. The Fritton Lake resort, the Somerleyton Duke's Head Pub, and Somerleyton Marina would not have investment, or would have closed if it were not for the intervention of the Somerleyton Estate. Income from small housing developments such as the site in Fritton, if it were to be allocated, would allow more investment into the local economy.

The site in Fritton is a logical housing site. Its development would relate well to the existing built-up area of the village. The site has a long road frontage which will allow the creation of a suitable vehicular access. The development would be socially sustainable as it would provide a mix of house types that would meet local needs. The development would be economically sustainable with economic benefits through construction and long-term patronage of local facilities.

Request to be heard?: Yes

Reason for Request to be heard:To ensure that the inspector understands our objections.

Attachments: REP61 - Trustees 1971 Settlement (PDF, 449 KB)(opens new window)

Rep ID: 62 / Respondent: Evolution Town Planning on behalf of Trustees 1971 Settlement Michael

Date Received: 1/20/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy RUR2

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: These representations comment on Policy RUR2 which deals with self-build housing in the countryside. We broadly support the policy which allows the delivery of self-build homes. As a Suffolk based planning practice, we are often instructed to help people with self-build projects so appreciate the need for this type of housing in this area. Self-Build homes are important as they meet an identified local need in Great Yarmouth. They are also a good source of work for local small businesses such as plumbers and electricians, so significantly benefit the local economy. We object to two parts of the policy. Firstly, the first paragraph part (a), and secondly part (e). We hope that the Council considers these amendments are sensible and that changes can be made to the policy.

The first paragraph and part (a) limit the development to a maximum of two dwellings. This is restrictive and the policy should be more flexible. There are a limited number of opportunities for small infill developments of the type proposed in the policy. The rural area of the Borough is small with a limited number of rural settlements. To ensure delivery, it would be sensible to have a limit of three homes per site. An increase in numbers would help site viability as the provision of services to sites, and in particular electricity, can be expensive. Allowing a higher number of self-build homes also gives some flexibility to deliver more smaller properties which would be less expensive and available to a broader range of people. Part (a) requires that developments take account of the 'prevailing density of the built-up area in the locality'. The sites which will be developed by this policy are small sites on the edge of villages. They will often have a range of densities around them. For example, there could be larger homes on the edge of village, and maybe smaller homes on the opposite side of a road such as terraced cottages or semi-detached homes. It would make sense to ensure that developments take account of the prevailing 'character' rather than 'density'. This would also provide some site-specific flexibility to deliver good development appropriate to its surroundings.

Suggested Modifications: We propose that the first paragraph and part (a) are changed to state up to 'three dwellings'. The final sentence of part (a) should be changed to: ...... 'taking account of the local character of the built-up area in the locality'.

The second part of the policy which should be altered, is part (e). This states that 'the proposal is not within a gap which contributes to the character of the landscape'. This is a broad statement and almost any development will be in a gap which contributes to the character of the landscape. The key issue is whether the proposal harms an important gap, which contributes to an important landscape. More detail would help in the policy or supporting text, for example if the gap was identified as important in a Conservation Area appraisal or Neighbourhood Plan, then there will be a policy justification to refuse development.

A balance must also be made between proposals which would result in a low level of harm and the benefits of delivering self-build homes which are, firstly, the delivery of homes, and secondly, meeting the areas self-build requirements, and thirdly, economic benefits from development.

The policy should be amended to state 'the proposal is not within an important gap within a settlement where development would cause significant harm to the character of the area'.

These changes are necessary to ensure that the policy is sound by being positively prepared and justified. We hope that these comments are helpful and that amendments can be made to the policy.

Request to be heard?: Yes

Reason for Request to be heard:To ensure that the inspector understands our objections.

Attachments: REP62 - Trustees 1971 Settlement (PDF, 282 KB)(opens new window)

Rep ID: 63 / Respondent: Badger Building (E. Anglia) Ltd Justin Coote

Date Received: 1/21/2025

Section of the Plan: 0

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Local Plan Viability Assessment

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound

Reasons: The comments below are in response to both the Local Plan Regulation 19 consultation and the consultation on the Great Yarmouth Community Infrastructure Levy (CIL) Draft Charging Schedule as both are underpinned by the Local Plan Viability Assessment December 2023 prepared by HDH. We believe that the Local Plan Viability Assessment (December 2023) is not sound and therefore the policies and plan that it supports are not sound in relation to Housing Development. The relevance of the viability assessment is not just the justification for HOU1 being viable and deliverable, but in addition the viability of other policies including HOU8, HOU9 and NAT3, which build in additional cost.

Representations were made in October 2023 during the viability assessment consultation, with supporting evidence provided based on actual costs from local developments. Our particular concern was the assumption of 5%-15% for site costs. The evidence provided supported our suggestion that an allowance of 40% to 55% should be used. I attach the previously submitted information together with information from a further 4 developments which support this position. HDH state:

"Having reviewed the information submitted with the above comments, some of these costs are included elsewhere in the appraisal, such as Design, survey, planning, legals, Building Control and NSBC costs - all of which are within fees, selling expenses - which are within marketing costs; and s106 costs which are allowed for specifically."

This statement is factually incorrect as the submitted evidence clearly shows design, survey, planning, legal, Building Control, NHBC, selling and S106 outside of the 40%-55% for site works costs. For clarity, site works costs include earthworks, roads, sewers, private drainage, landscaping (hard and soft), fencing, gardens, open space works, etc.

HDH go on to refer to viabilities carried out by neighbouring authorities as a point of reference. Most of the neighbouring authorities' viabilities are several years out of date and therefore not reflective of the current standards and build costs.

HDH's use of 5%-15%, if derived from historic data, is not reflective of either current costs or current standards. Historical cost data will not include the increased external works costs reflective of current standards. Current requirements which may not be reflected in historical cost data include SUDS for surface water drainage (swales, rain gardens, etc), which are in addition to the positive drainage network in most instances and the increased width of roads and footpaths now being sought by the highway authority. Furthermore, there has been an increase in service connections. costs (water/sewerage/electrical) which has not been accounted for. The percentage also does not reflect the recent and significant increase in groundworks costs generally. The 5%-15% allowance has never been realistic site infrastructure including roads and sewers in addition to open space, landscaping, boundary treatments, private drainage, etc.

The use of the lower percentage for site costs results in overall lower development costs making the viability appear better, especially when the revenues used are higher than are realistic and land values lower than would be expected by landowners to bring a site forward.

The Viability Assessment applies £/m² sales revenue to larger NDSS size properties. This is flawed:

applying the same £/m² sales revenue to a larger area is not realistic. There are ceiling values for

dwellings (i.e. 2, 3, 4 bed) which will not proportionately increase will additional area.

The land values used in the viability assessment are also not at a level which mean landowners agree

to sell.

We have commissioned Pathfinder to prepare a response which is attached and provides further

comment in respect of costs and values, particularly the affordable revenues used in the viability.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments:

REP 63 - Badger Building (Attachment 1) (PDF, 268 KB)(opens new window)

REP63 - Badger Building (Attachment 2) (PDF, 446 KB)(opens new window)

REP63 - Badger Building (Attachment 3) (PDF, 597 KB)

REP63 - Badger Building (Attachment 4) (PDF, 423 KB)

REP63 - Badger Building (Attachment 5) (Microsoft Excel, 23 KB)(opens new window)

REP63 - Badger Building (Attachment 6) (PDF, 439 KB)(opens new window)

REP63 - Badger Building (Attachment 7) (PDF, 227 KB)(opens new window)

REP63 - Badger Building (Attachment 8) (PDF, 143 KB)

Rep ID: 64 / Respondent: Badger Building (E. Anglia) Ltd Justin Coote

Date Received: 1/21/2025

Section of the Plan: 7

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HOU1

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound

Reasons: The proposed policy requirement for 25% affordable housing is not sound. The viability assessment supporting the increase is flawed, please refer to previous comments. In addition, "First Homes" no longer recognised in the latest NPPF.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 65 / Respondent: Badger Building (E. Anglia) Ltd Justin Coote

Date Received: 1/21/2025

Section of the Plan: 7

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HOU4

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound

Reasons: Although we do not consider this policy to be unsound, when considered in the context of the flawed viability assessment, the mix will need to be amended to increase the overall average area of dwellings on any given development, to assist in making them viable.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 66 / Respondent: Badger Building (E. Anglia) Ltd Justin Coote

Date Received: 1/21/2025

Section of the Plan: 7

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HOU8

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound

Reasons: The policy is not sound in the context of the points previously made in relation to the viability assessment. This policy will add cost to developments but brings about no increase in selling prices which are determined by the local market.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 67 / Respondent: Badger Building (E. Anglia) Ltd Justin Coote

Date Received: 1/21/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT3

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound

Reasons: The council aspiration of 20% BNG is commendable but is not a sound policy aspiration, and not deliverable on 99% of sites. The mandatory 10% is challenging enough and will result in a loss of dwellings across the allocations due to additional land being required to accommodate the gains required (i.e. wildflower meadows, etc). A 20% betterment would result in a significant loss of dwellings on allocations, potentially as much as 25 -30% of the allocated units, particularly if the site has a higher biodiversity base line. There will also be a conflict with the open space SPD in terms of BNG areas not meeting local need for play space, or recreational use (sports pitches, informal play, allotments) resulting in additional areas being required solely for BNG. This rapidly becomes a situation of diminishing returns.

The statement at 16.15, "It is likely that many of the greenfield development sites as identified in this plan currently have a very low biodiversity baseline", is unsubstantiated with no evidence base to support it. We would suggest it is not an accurate statement. We would also point out that we are not aware of any, private or public, offsite BNG credits being offered in the borough. This will result in a real risk of sites not being deliverable. There is no logic to consider sites within the development limits of Great Yarmouth, Gorleston-on-sea, Bradwell and Caister-on Sea separately to other sites. Why have development boundaries not been extended to include proposed allocations as the Council are proposing this is where development will occur? Particularly where proposed allocations are adjacent to the existing development boundary. The 10% mandatory requirement should apply to all sites. We would go further and suggest that the Borough lobby that the exemption to BNG is extended to include brownfield development. Many brownfield sites which have been left for a period develop into what is known as "open mosaic habitat" (see Britain's Habitats 2nd Edition 2020 - Lake, Lilley, Still and Swash for a more detailed explanation of this phenomena). This can be particularly rich in species which are good at colonization and has a very high scoring baseline, meaning the resulting gain required is substantial both in terms of space and cost. Such habitat is not easily replicated, meaning that already challenging sites in terms of viability will become undeliverable. Finally, at a recent Borough Development Forum it was stated by officers that the aspiration for 20% BNG assumed that private gardens could be included in the metric calculation. This is an incorrect assumption and therefore the basis of the policy aspiration is not sound.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 68 / Respondent: Badger Building (E. Anglia) Ltd Justin Coote

Date Received: 1/21/2025

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy OSS1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: The above comments are made, in some cases again following earlier consultation, to inform the plan making process, and to show where we believe proposed policy will not assist housing delivery in the timely manner now set out by the revised National Planning Policy Framework (NPPF). The plan presently being consulted on doesn't reflect the aims of that document, as published in December and which seeks to not only significantly increase the housing supply, in terms of the number of properties built, but also increase the speed of delivery. We conclude that the recent revisions to the NPPF, in relation to the methodology for calculating dwelling numbers in the plan, will mean that Great Yarmouth may have to increase its annual supply of dwellings by a figure more than 150 units. We conclude that this figure is not achievable by a reliance on additional windfall sites coming forward and will require further allocations to be made. If any necessary reassessment of housing numbers, (arising from the revisions to the NPPF), determines that additional land should be allocated then we draw attention to our site in Bradwell on Beccles Road. This presently is allocated for 150 units. Discussions with the highway authority have indicated previously that they would have no objection to an allocation here of up to 250 units, subject to certain conditions. Given the change in emphasis on highway objections now set out in the NPPF there may be scope for further development up to the original figure of 600 dwellings we originally set out. We can accommodate such an increase in our arrangement with the landowners, who are keen to proceed, and we have demonstrated through our past actions that we can deliver on land in the Borough, building quality houses that are attractive in the marketplace.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 69 / Respondent: Graham Durhill

Date Received: 1/16/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB21 4.205

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Policy URB21 is unsound given the number of houses being proposed without another access off the A47 to serve the development. Links Road is not adequate for the extra traffic which would be generated as existing volumes already cause difficulties for vehicles accessing and emerging from side roads serving the residential areas.

There would also be an impact on the existing A47/Links Road junction leading to congestion on the approach roads and thereby delays for ambulances from the nearby operating centre.

No development has been achieved so far, although the site is in the existing Local Plan, because National Highways do not want another access created off the A47 and the costs of improving the existing junction affect the viability of any development.

The number and mix of houses proposed would also create a more densely populated estate compared to those in the vicinity changing the character of the area.

If such a development went ahead the long term sustainability of integrated transport would not be achieved.

Suggested Modifications: A significant reduction in the number of houses would be appropriate with around 50 being the acceptable density served by a single access.

This will make the Local Plan sound.

Request to be heard?: Yes

Reason for Request to be heard:My submission challenges the sustainability of a proposal and given my expertise in the planning and transportation field I consider my contributions would be of benefit to the Inspector.

Attachments: N/A

Rep ID: 70 / Respondent: Reuben Dunn

Date Received: 1/17/2025

Section of the Plan: 5

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CAS1

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: The plan does not provide social assisted living accommodation or facilities.

Suggested Modifications: A scheme providing similar facilities to The Lawns but updated for current and future needs. This would fill the gap between sheltered housing and care homes.

The demography is aging and more and more elderly people will require fully accessible and safe accommodation.

Sheltered housing as suggested does not provide any level of care and certainly none outside of normal working hours.

Request to be heard?: Yes

Reason for Request to be heard:To elaborate on the statement made.

Attachments: N/A

Rep ID: 71 / Respondent: Linda Lodge

Date Received: 1/18/2025

Section of the Plan: 5

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CAS1

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Although the plan shows some housing for sheltered accommodation it does not show any housing with care/ assisted living. The demographics for this area is of an aging population.

Suggested Modifications: There needs to be either social or private provision for housing with care. The only other facility, as far as I know, is The Lawns which was built in the 70's and really is becoming 'not fit for purpose'.

Your plan includes a medical centre and local shops. These facilities will definitely be an asset if housing with care is provided. Apart from care homes there are no facilities with 24 hour care available.

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments: N/A

Rep ID: 72 / Respondent: Caroline Beard

Date Received: 1/19/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Bradwell

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Does not comply with Duty to Co-operate

Reasons: I object to further development of building s in Bradwell. Most people object to more new builds and the majority are not being listened to. There is a distinct lack of democracy where this subject is concerned. Climate change and wildlife welfare is not seriously being considered. I have seen a massive decline in fauna on Wheatcroft Farm since farmland and woodland has been built upon. Where are the solar panels on the new builds/ renewable energy? I have seen deterioration in the village at least in the last 5 years due to rising crime and increase in traffic. Probably caused by a lack of facilities and an increasing village population. . There is no consideration in new builds for an increasing elderly population who may no longer be able to live in their house and would like to move to a bungalow/ flat or assisted living and therefore possibly reducing the need of medical provision. Plus the loss of the GP surgery on Cornfields Estate.

Suggested Modifications: Please refer to my observations and objections above.

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments: N/A

Rep ID: 73 / Respondent: Davies and Co on behalf of Barbara

Date Received: 1/21/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Figure 16

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Complies with Duty to Co-operate

Reasons: The defined Development Limits for Hemsby indicated in Figure 16 should be adjusted to incorporate the indicated housing allocation identified by Policy HEM1. This is a formally proposed housing allocation which provides both for Hemsby and the Borough as a whole and will assist in contributing to a range of community needs. It is an intrinsic part of the settlement that has been brought forward through the adopted Neighbourhood Plan. Therefore it should fall within the development limits of the settlement.

See also representation concerning the inclusion of all allocated sites within Development Limits to accord with the NPPF and the presumption in favour of sustainable development.

Suggested Modifications: Amend the Development Limit defined on Figure 16 to incorporate HEM1

Request to be heard?: No

Reason for Request to be heard:

Attachments: N/A

Rep ID: 74 / Respondent: Davies and Co on behalf of Barbara

Date Received: 1/21/2025 12:07:00 PM

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HEM1

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Policy HEM1 is supported. This is an important allocation, both for Hemsby and the Borough as a whole. It is a unique site in that it also affords an opportunity to provide for the reinstatement of dwellings that are likely to be lost to the settlement due to coastal erosion. It's inclusion will also help support the continuing provision of local facilities and enable other benefits, such as flood remediation.

Suggested Modifications: None

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 75 / Respondent: Davies and Co on behalf of Barbara

Date Received: 1/21/2025

Section of the Plan: 0

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Appendix 8

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Appendix 8 indicates 164 new dwelling allocations for Hemsby but doesn't indicate the 42 roll-back plots which will - in effect - be new allocations. Once the at-risk coastal dwellings are lost to erosion impacts there is a net loss to the Borough.

Appendices A8.1; A8.2 and A8.3 should show the proposed total of 206 dwellings for HEM1 but may require some qualification by reference to the special provisions for 42 dwellings in Policy HEM1.

Suggested Modifications: Appendices A8.1; A8.2 and A8.3 should show the proposed total of 206 dwellings for HEM1 but may require some qualification by reference to the special provisions for 42 dwellings in Policy HEM1.

Request to be heard?: No

Reason for Request to be heard:

Attachments: N/A

Rep ID: 76 / Respondent: Davies and Co on behalf of Barbara

Date Received: 1/21/2025

Section of the Plan: 0

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policies Map

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Complies with Duty to Co-operate

Reasons: The Policies Map should be amended to show the revised Development Limits that arise from housing allocations in order to be compliant with NPPF guidance and ensure that proposals accord with the presumption in favour of sustainable development. If the allocated areas are omitted from Development Limits then there is a policy confliction, in that development proposals will not lie within an area that would normally be considered appropriate for development (i.e. outside of defined development limits).

Suggested Modifications: The Policies Map should be amended to show the revised Development Limits that arise from housing and other allocations.

Request to be heard?: No

Reason for Request to be heard:

Attachments: N/A

Rep ID: 77 / Respondent: Baytree Surveying on behalf of Crocus Homes Ltd

Date Received: 1/13/2025

Section of the Plan: 0

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Local Plan Viability Assessment

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: I have been appointed to make representations relating to the above Regulation 19 Submission of the Great Yarmouth Local Plan on behalf of my client Crocus Homes, who are interested in a number of sites within the borough. I trust you will find the comments of assistance, which relate to the Regulation 19 Consultation Document and the 'The Local Plan Viability Assessment - December 2023' undertaken by HDH. If it would assist the Council to discuss any of the following comments, then please do not hesitate to contact me or my client.

We wish to make comment specifically on:

1. The Draft Local Plan is underpinned by: The Local Plan Viability Assessment.

Draft Local Plan Policies are: Supported and underpinned by:

• The Local Plan Viability Assessment - December 2023 undertaken by HDH

The relevance of the viability assessment is not just the justification for HOU1 being viable and therefore deliverable, which seeks 25% affordable housing (60% affordable rent, 25% 1st homes, 15% other LCHO - note 1st Homes are no longer a requirement of the NPPF) but in addition the viability of a range of other policies which build in additional costs including:

• Hou8 - Housing space standards (NDSS)

• Hou9 - Accessibility Standards: All new homes to comply with M4(2), 10% of affordable housing to be M4(3)

• BNG: NAT 3 - at 20% (rather than 10%)

• Nutrient Neutrality - Nat 5 (which was not tested in The Local Plan Viability Assessment)

2. Inadequacy of draft Viability Assessment

A draft Viability Assessment was sent out to consultation on the 9th October 2023.

The consultation only ran for 15 days (included in which was the half term holidays) which will have limited responses. Furthermore, those limited responses have been largely dismissed by HDH in the December 2023 version of their report. We remain extremely concerned about a number of assumptions the most significant of which are explored below:

3. External Works Costs

The base build cost of homes in the HDH work is based on utilising the BCIS. This however does not include external works to either individual plots, or the wider estate. HDH note: 'Many of these items will depend on individual site circumstances and can only properly be estimated following a detailed assessment of each site,' which of course is true.

External works include all added costs associated with the site curtilage of the built areas, such as garden spaces (including paths, patios, fencing), incidental landscaping costs (including trees and hedges, and soft and hard landscaping), estate roads and connections to the site infrastructure works such as utilities and sewers.

HDH consulted on the use of external works allowances: 'ranging from 5% of build costs for the smaller sites and flatted schemes within the urban area, to 15% for the larger greenfield schemes'. All responses to the October 2024 consultation on this point suggested that such allowances were far too low.

However, HDH made no change to there assumption (typically 15% of base build costs being used to calculate all plot and external works costs) principally relying on the circular argument that it's the same assumption used in many other plan wide viability studies. However, we would note in more recent studies the inadequacy of this standard assumption relying only on it previously being accepted (and no analysis of actual costs in example schemes) is being noted.

For example, in Test Valley BC December 2023 Strategic Site Viability Testing report they use 15% of base construction costs for external works and 15% for Site infrastructure (utilities, roads etc) i.e. 30% in total. This is more in keeping with earlier representations which included:

'Attached RUA letter with their typical benchmark allowances which as a % of build cost is 43%. We attach examples of recently completed or nearly completed sites which shows site costs for at 44% and 43% for larger and medium sized developments but at 55% for a smaller scheme. The increasing requirement for above ground SuDs features (swales, rain gardens, basins, etc) together with BNG will increase the costs.'

The earlier examples are resubmitted as attached (build costs only) with three further examples indicating that the proposed 15% external works cost is wholly inadequate. (We note in response to the October 2023 submissions no comments were made by HDH or requests for measurements and rates etc to be analysed which are available, or for advice to be sought from suitably qualified Quantity Surveyors etc.)

4. Value of Affordable Housing

The October 2023 consultation proposed:

• Affordable Rented homes attribute a value of £1,735m2 (60% of affordable homes in total)

• And Affordable Home Ownership products attribute a value at 70% of the market value (40% of affordable homes in total)

The December 2024 report considered feedback but used assumptions that were unaltered, despite submitted evidence that actual values paid to developers by RP's were far lower.

This mismatch is due to several factors:

• HDH do not take into account the impact of estate charges in further discounting net rents. There definition of Affordable Rent does not conform to the Governments in so far as the Government definition goes onto note that ART must not exceed 80% of the market rent 'inclusive of service charges'.

• HDH undertake their own modelling based on a range of assumptions that bare no relationship to how the actual market performs. The supply of affordable housing delivered by developers interacts with the financial capacity of Registered Providers to acquire homes. If an RP is not sufficiently successful in acquiring homes they will increase their offer level, equally once their capacity is satisfied offer levels reduce. It is key to understand what the market is paying, not what an individual thinks they should be allowed to pay.

• It has been well documented in recent months that the market to acquire affordable homes delivered through S106 agreements is at best struggling. This is probably best analysed and summarised in the recent HBF report: 'Bid Farewell' (https://www.hbf.co.uk/documents/14180/Bid_Farewell_AH_S106_report_Nov_2024.pdf), as well as in the Governments response to the crisis: 'Register to sell and buy Section 106 affordable homes' (https://www.gov.uk/guidance/register-to-sell-and-buy-section-106-affordable-homes).

We previously noted in October: 'Rather than seeking abstract values we have analysed recent transactions in the market place where offers have been accepted by housebuilders from RP's after extensive marketing:

• Ormesby 7 homes for rent (2x1BF, 4x2BH, 1x3BH) plus 1x2BH for Shared Ownership. Sept 23, the highest offer having approached 8 RP's was £1,553m2

• Freethorpe 2 homes for rent (2x2BH) plus 1x3BH for Shared Ownership. December 2022, the highest offer having approached 8 RP's was £1,868m2

• Martham 10 homes for rent (5x1BB, 5X3BB), Plus 6 homes for Shared Ownership sale (2x1BB, 4x2BB). July 21, the highest offer having approached 8 RP's was £2,024m2

This evidence shows the assumptions used by HDH are to high and should be adjusted accordingly. In reality RP's don't price individual property types or tenures, but instead the blended scheme. Drilling down to the detailed offer per property types and tenure is simply not possible, and when RP's do it their models produce lower offers in general than the blended scheme.'

However, since this data was supplied the market has worsened as noted above. For example, in Rollsby a scheme of 2 affordable homes (2x79m2 2B4PH), one for rent and one for Shared Ownership were extensively marketed on two occasions to all active Registered Providers in the Borough and received a blended offer of £1,202.53m2 in June 2024.

It should be noted that the NPPF requitement for First Homes no longer applies. Therefore, if overall viability is not to be significantly damaged, the requirement for 25% of affordable housing to be First Homes must be switched to another low-cost home ownership product.

5. Conclusion

Further consideration of the viability and therefore deliverability of policies contained within the draft Local plan are required to ensure it is robust. Inadequate assumptions in two key areas of 'The Local Plan Viability Assessment' - Dec 2023 primarily lead to this concern:

• Inadequate assumptions relating to external works costs

• Overly optimistic assumptions relating to the value of affordable housing

In addition, the revised NPPF removes the requirement for First Homes, which requires a response from the council which does not further damage viability.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP77-81 - Crocus Homes (Microsoft Excel, 23 KB)

Rep ID: 78 / Respondent: Baytree Surveying on behalf of Crocus Homes Ltd

Date Received: 1/13/2025

Section of the Plan: 7

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HOU1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

We wish to make comment specifically on:

1. The Draft Local Plan is underpinned by: The Local Plan Viability Assessment.

Draft Local Plan Policies are: Supported and underpinned by:

• The Local Plan Viability Assessment - December 2023 undertaken by HDH

• HOU8 - Housing space standards (NDSS)

• HOU9 - Accessibility Standards: All new homes to comply with M4(2), 10% of affordable housing to be M4(3)

• BNG: NAT 3 - at 20% (rather than 10%)

• Nutrient Neutrality - Nat 5 (which was not tested in The Local Plan Viability Assessment)

2. Inadequacy of draft Viability Assessment

A draft Viability Assessment was sent out to consultation on the 9th October 2023.

3. External Works Costs

4. Value of Affordable Housing

The October 2023 consultation proposed:

• Affordable Rented homes attribute a value of £1,735m2 (60% of affordable homes in total)

• And Affordable Home Ownership products attribute a value at 70% of the market value (40% of affordable homes in total)

The December 2024 report considered feedback but used assumptions that were unaltered, despite submitted evidence that actual values paid to developers by RP's were far lower.

This mismatch is due to several factors:

• Ormesby 7 homes for rent (2x1BF, 4x2BH, 1x3BH) plus 1x2BH for Shared Ownership. Sept 23, the highest offer having approached 8 RP's was £1,553m2

• Freethorpe 2 homes for rent (2x2BH) plus 1x3BH for Shared Ownership. December 2022, the highest offer having approached 8 RP's was £1,868m2

• Martham 10 homes for rent (5x1BB, 5X3BB), Plus 6 homes for Shared Ownership sale (2x1BB, 4x2BB). July 21, the highest offer having approached 8 RP's was £2,024m2

5. Conclusion

• Inadequate assumptions relating to external works costs

• Overly optimistic assumptions relating to the value of affordable housing

In addition, the revised NPPF removes the requirement for First Homes, which requires a response from the council which does not further damage viability.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP77-81 - Crocus Homes (Microsoft Excel, 23 KB)(opens new window)

Rep ID: 79 / Respondent: Baytree Surveying on behalf of Crocus Homes Ltd

Date Received: 1/13/2025

Section of the Plan: 7

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HOU9

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

We wish to make comment specifically on:

1. The Draft Local Plan is underpinned by: The Local Plan Viability Assessment.

Draft Local Plan Policies are: Supported and underpinned by:

• The Local Plan Viability Assessment - December 2023 undertaken by HDH

• Hou8 - Housing space standards (NDSS)

• Hou9 - Accessibility Standards: All new homes to comply with M4(2), 10% of affordable housing to be M4(3)

• BNG: NAT 3 - at 20% (rather than 10%)

• Nutrient Neutrality - Nat 5 (which was not tested in The Local Plan Viability Assessment)

2. Inadequacy of draft Viability Assessment

A draft Viability Assessment was sent out to consultation on the 9th October 2023.

3. External Works Costs

4. Value of Affordable Housing

The October 2023 consultation proposed:

• Affordable Rented homes attribute a value of £1,735m2 (60% of affordable homes in total)

• And Affordable Home Ownership products attribute a value at 70% of the market value (40% of affordable homes in total)

The December 2024 report considered feedback but used assumptions that were unaltered, despite submitted evidence that actual values paid to developers by RP's were far lower.

This mismatch is due to several factors:

• Ormesby 7 homes for rent (2x1BF, 4x2BH, 1x3BH) plus 1x2BH for Shared Ownership. Sept 23, the highest offer having approached 8 RP's was £1,553m2

• Freethorpe 2 homes for rent (2x2BH) plus 1x3BH for Shared Ownership. December 2022, the highest offer having approached 8 RP's was £1,868m2

• Martham 10 homes for rent (5x1BB, 5X3BB), Plus 6 homes for Shared Ownership sale (2x1BB, 4x2BB). July 21, the highest offer having approached 8 RP's was £2,024m2

5. Conclusion

• Inadequate assumptions relating to external works costs

• Overly optimistic assumptions relating to the value of affordable housing

In addition, the revised NPPF removes the requirement for First Homes, which requires a response from the council which does not further damage viability.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP77-81 - Crocus Homes (Microsoft Excel, 23 KB)

Rep ID: 80 / Respondent: Baytree Surveying on behalf of Crocus Homes Ltd

Date Received: 1/13/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT3

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

I trust you will find the comments of assistance, which relate to the Regulation 19 Consultation Document and the 'The Local Plan Viability Assessment - December 2023' undertaken by HDH. If it would assist the Council to discuss any of the following comments, then please do not hesitate to contact me or my client.

We wish to make comment specifically on:

1. The Draft Local Plan is underpinned by: The Local Plan Viability Assessment.

Draft Local Plan Policies are: Supported and underpinned by:

• The Local Plan Viability Assessment - December 2023 undertaken by HDH

• Hou8 - Housing space standards (NDSS)

• Hou9 - Accessibility Standards: All new homes to comply with M4(2), 10% of affordable housing to be M4(3)

• BNG: NAT 3 - at 20% (rather than 10%)

• Nutrient Neutrality - Nat 5 (which was not tested in The Local Plan Viability Assessment)

2. Inadequacy of draft Viability Assessment

A draft Viability Assessment was sent out to consultation on the 9th October 2023.

3. External Works Costs

4. Value of Affordable Housing

The October 2023 consultation proposed:

• Affordable Rented homes attribute a value of £1,735m2 (60% of affordable homes in total)

• And Affordable Home Ownership products attribute a value at 70% of the market value (40% of affordable homes in total)

The December 2024 report considered feedback but used assumptions that were unaltered, despite submitted evidence that actual values paid to developers by RP's were far lower.

This mismatch is due to several factors:

• Ormesby 7 homes for rent (2x1BF, 4x2BH, 1x3BH) plus 1x2BH for Shared Ownership. Sept 23, the highest offer having approached 8 RP's was £1,553m2

• Freethorpe 2 homes for rent (2x2BH) plus 1x3BH for Shared Ownership. December 2022, the highest offer having approached 8 RP's was £1,868m2

• Martham 10 homes for rent (5x1BB, 5X3BB), Plus 6 homes for Shared Ownership sale (2x1BB, 4x2BB). July 21, the highest offer having approached 8 RP's was £2,024m2

5. Conclusion

• Inadequate assumptions relating to external works costs

• Overly optimistic assumptions relating to the value of affordable housing

In addition, the revised NPPF removes the requirement for First Homes, which requires a response from the council which does not further damage viability.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP77-81 - Crocus Homes (Microsoft Excel, 23 KB)(opens new window)

Rep ID: 81 / Respondent: Baytree Surveying on behalf of Crocus Homes Ltd

Date Received: 1/13/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT5

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

We wish to make comment specifically on:

1. The Draft Local Plan is underpinned by: The Local Plan Viability Assessment.

Draft Local Plan Policies are: Supported and underpinned by:

• The Local Plan Viability Assessment - December 2023 undertaken by HDH

• Hou8 - Housing space standards (NDSS)

• Hou9 - Accessibility Standards: All new homes to comply with M4(2), 10% of affordable housing to be M4(3)

• BNG: NAT 3 - at 20% (rather than 10%)

• Nutrient Neutrality - Nat 5 (which was not tested in The Local Plan Viability Assessment)

2. Inadequacy of draft Viability Assessment

A draft Viability Assessment was sent out to consultation on the 9th October 2023.

3. External Works Costs

4. Value of Affordable Housing

The October 2023 consultation proposed:

• Affordable Rented homes attribute a value of £1,735m2 (60% of affordable homes in total)

• And Affordable Home Ownership products attribute a value at 70% of the market value (40% of affordable homes in total)

The December 2024 report considered feedback but used assumptions that were unaltered, despite submitted evidence that actual values paid to developers by RP's were far lower.

This mismatch is due to several factors:

• Ormesby 7 homes for rent (2x1BF, 4x2BH, 1x3BH) plus 1x2BH for Shared Ownership. Sept 23, the highest offer having approached 8 RP's was £1,553m2

• Freethorpe 2 homes for rent (2x2BH) plus 1x3BH for Shared Ownership. December 2022, the highest offer having approached 8 RP's was £1,868m2

• Martham 10 homes for rent (5x1BB, 5X3BB), Plus 6 homes for Shared Ownership sale (2x1BB, 4x2BB). July 21, the highest offer having approached 8 RP's was £2,024m2

5. Conclusion

• Inadequate assumptions relating to external works costs

• Overly optimistic assumptions relating to the value of affordable housing

In addition, the revised NPPF removes the requirement for First Homes, which requires a response from the council which does not further damage viability.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP77-81 - Crocus Homes (Microsoft Excel, 23 KB)(opens new window)

Rep ID: 82 / Respondent: Pathfinder Development Consultants on behalf of Cripps Developments

Date Received: 1/13/2025

Section of the Plan: 0

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Local Plan Viability Assessment

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

I am a Chartered Surveyor with over 35 years post qualification experience specialising in the delivery of affordable housing, within the eastern region, working as a director of Pathfinder. Pathfinder are a consultancy offering services that assist in the delivery of affordable housing, site identification and appraisal, and in land acquisition. Our clients include national and regional house builders, as well as local developers, and land promotion organizations, individual landowners, Registered Providers and Local Authorities.

We wish to make comment specifically on:

1. The Draft Local Plan is underpinned by: The Local Plan Viability Assessment.

Draft Local Plan Policies are: Supported and underpinned by:

• The Local Plan Viability Assessment - December 2023 undertaken by HDH

• Hou8 - Housing space standards (NDSS)

• Hou9 - Accessibility Standards: All new homes to comply with M4(2), 10% of affordable housing to be M4(3)

• BNG: NAT 3 - at 20% (rather than 10%)

• Nutrient Neutrality - Nat 5 (which was not tested in The Local Plan Viability Assessment)

2. Inadequacy of draft Viability Assessment

A draft Viability Assessment was sent out to consultation on the 9th October 2023.

3. External Works Costs

4. Value of Affordable Housing

The October 2023 consultation proposed:

• Affordable Rented homes attribute a value of £1,735m2 (60% of affordable homes in total)

• And Affordable Home Ownership products attribute a value at 70% of the market value (40% of affordable homes in total)

The December 2024 report considered feedback but used assumptions that were unaltered, despite submitted evidence that actual values paid to developers by RP's were far lower.

This mismatch is due to several factors:

• Ormesby 7 homes for rent (2x1BF, 4x2BH, 1x3BH) plus 1x2BH for Shared Ownership. Sept 23, the highest offer having approached 8 RP's was £1,553m2

• Freethorpe 2 homes for rent (2x2BH) plus 1x3BH for Shared Ownership. December 2022, the highest offer having approached 8 RP's was £1,868m2

• Martham 10 homes for rent (5x1BB, 5X3BB), Plus 6 homes for Shared Ownership sale (2x1BB, 4x2BB). July 21, the highest offer having approached 8 RP's was £2,024m2

5. Conclusion

• Inadequate assumptions relating to external works costs

• Overly optimistic assumptions relating to the value of affordable housing

In addition, the revised NPPF removes the requirement for First Homes, which requires a response from the council which does not further damage viability.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP82-86 - Cripps Developments (Microsoft Excel, 23 KB)(opens new window)

Rep ID: 83 / Respondent: Pathfinder Development Consultants on behalf of Cripps Developments

Date Received: 1/13/2025

Section of the Plan: 7

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HOU1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

We wish to make comment specifically on:

1. The Draft Local Plan is underpinned by: The Local Plan Viability Assessment.

Draft Local Plan Policies are: Supported and underpinned by:

• The Local Plan Viability Assessment - December 2023 undertaken by HDH

• Hou8 - Housing space standards (NDSS)

• Hou9 - Accessibility Standards: All new homes to comply with M4(2), 10% of affordable housing to be M4(3)

• BNG: NAT 3 - at 20% (rather than 10%)

• Nutrient Neutrality - Nat 5 (which was not tested in The Local Plan Viability Assessment)

2. Inadequacy of draft Viability Assessment

A draft Viability Assessment was sent out to consultation on the 9th October 2023.

3. External Works Costs

4. Value of Affordable Housing

The October 2023 consultation proposed:

• Affordable Rented homes attribute a value of £1,735m2 (60% of affordable homes in total)

• And Affordable Home Ownership products attribute a value at 70% of the market value (40% of affordable homes in total)

The December 2024 report considered feedback but used assumptions that were unaltered, despite submitted evidence that actual values paid to developers by RP's were far lower.

This mismatch is due to several factors:

• Ormesby 7 homes for rent (2x1BF, 4x2BH, 1x3BH) plus 1x2BH for Shared Ownership. Sept 23, the highest offer having approached 8 RP's was £1,553m2

• Freethorpe 2 homes for rent (2x2BH) plus 1x3BH for Shared Ownership. December 2022, the highest offer having approached 8 RP's was £1,868m2

• Martham 10 homes for rent (5x1BB, 5X3BB), Plus 6 homes for Shared Ownership sale (2x1BB, 4x2BB). July 21, the highest offer having approached 8 RP's was £2,024m2

5. Conclusion

• Inadequate assumptions relating to external works costs

• Overly optimistic assumptions relating to the value of affordable housing

In addition, the revised NPPF removes the requirement for First Homes, which requires a response from the council which does not further damage viability.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP82-86 - Cripps Developments (Microsoft Excel, 23 KB)(opens new window)

Rep ID: 84 / Respondent: Pathfinder Development Consultants on behalf of Cripps Developments

Date Received: 1/13/2025

Section of the Plan: 7

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HOU9

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

We wish to make comment specifically on:

1. The Draft Local Plan is underpinned by: The Local Plan Viability Assessment.

Draft Local Plan Policies are: Supported and underpinned by:

• The Local Plan Viability Assessment - December 2023 undertaken by HDH

• Hou8 - Housing space standards (NDSS)

• Hou9 - Accessibility Standards: All new homes to comply with M4(2), 10% of affordable housing to be M4(3)

• BNG: NAT 3 - at 20% (rather than 10%)

• Nutrient Neutrality - Nat 5 (which was not tested in The Local Plan Viability Assessment)

2. Inadequacy of draft Viability Assessment

A draft Viability Assessment was sent out to consultation on the 9th October 2023.

3. External Works Costs

4. Value of Affordable Housing

The October 2023 consultation proposed:

• Affordable Rented homes attribute a value of £1,735m2 (60% of affordable homes in total)

• And Affordable Home Ownership products attribute a value at 70% of the market value (40% of affordable homes in total)

The December 2024 report considered feedback but used assumptions that were unaltered, despite submitted evidence that actual values paid to developers by RP's were far lower.

This mismatch is due to several factors:

• Ormesby 7 homes for rent (2x1BF, 4x2BH, 1x3BH) plus 1x2BH for Shared Ownership. Sept 23, the highest offer having approached 8 RP's was £1,553m2

• Freethorpe 2 homes for rent (2x2BH) plus 1x3BH for Shared Ownership. December 2022, the highest offer having approached 8 RP's was £1,868m2

• Martham 10 homes for rent (5x1BB, 5X3BB), Plus 6 homes for Shared Ownership sale (2x1BB, 4x2BB). July 21, the highest offer having approached 8 RP's was £2,024m2

5. Conclusion

• Inadequate assumptions relating to external works costs

• Overly optimistic assumptions relating to the value of affordable housing

In addition, the revised NPPF removes the requirement for First Homes, which requires a response from the council which does not further damage viability.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP82-86 - Cripps Developments (Microsoft Excel, 23 KB)(opens new window)

Rep ID: 85 / Respondent: Pathfinder Development Consultants on behalf of Cripps Developments

Date Received: 1/13/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT3

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

We wish to make comment specifically on:

1. The Draft Local Plan is underpinned by: The Local Plan Viability Assessment.

Draft Local Plan Policies are: Supported and underpinned by:

• The Local Plan Viability Assessment - December 2023 undertaken by HDH

• Hou8 - Housing space standards (NDSS)

• Hou9 - Accessibility Standards: All new homes to comply with M4(2), 10% of affordable housing to be M4(3)

• BNG: NAT 3 - at 20% (rather than 10%)

• Nutrient Neutrality - Nat 5 (which was not tested in The Local Plan Viability Assessment)

2. Inadequacy of draft Viability Assessment

A draft Viability Assessment was sent out to consultation on the 9th October 2023.

3. External Works Costs

4. Value of Affordable Housing

The October 2023 consultation proposed:

• Affordable Rented homes attribute a value of £1,735m2 (60% of affordable homes in total)

• And Affordable Home Ownership products attribute a value at 70% of the market value (40% of affordable homes in total)

The December 2024 report considered feedback but used assumptions that were unaltered, despite submitted evidence that actual values paid to developers by RP's were far lower.

This mismatch is due to several factors:

• Ormesby 7 homes for rent (2x1BF, 4x2BH, 1x3BH) plus 1x2BH for Shared Ownership. Sept 23, the highest offer having approached 8 RP's was £1,553m2

• Freethorpe 2 homes for rent (2x2BH) plus 1x3BH for Shared Ownership. December 2022, the highest offer having approached 8 RP's was £1,868m2

• Martham 10 homes for rent (5x1BB, 5X3BB), Plus 6 homes for Shared Ownership sale (2x1BB, 4x2BB). July 21, the highest offer having approached 8 RP's was £2,024m2

5. Conclusion

• Inadequate assumptions relating to external works costs

• Overly optimistic assumptions relating to the value of affordable housing

In addition, the revised NPPF removes the requirement for First Homes, which requires a response from the council which does not further damage viability.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP82-86 - Cripps Developments (Microsoft Excel, 23 KB)(opens new window)

Rep ID: 86 / Respondent: Pathfinder Development Consultants on behalf of Cripps Developments

Date Received: 1/13/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT5

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

We wish to make comment specifically on:

1. The Draft Local Plan is underpinned by: The Local Plan Viability Assessment.

Draft Local Plan Policies are: Supported and underpinned by:

• The Local Plan Viability Assessment - December 2023 undertaken by HDH

• Hou8 - Housing space standards (NDSS)

• Hou9 - Accessibility Standards: All new homes to comply with M4(2), 10% of affordable housing to be M4(3)

• BNG: NAT 3 - at 20% (rather than 10%)

• Nutrient Neutrality - Nat 5 (which was not tested in The Local Plan Viability Assessment)

2. Inadequacy of draft Viability Assessment

A draft Viability Assessment was sent out to consultation on the 9th October 2023.

3. External Works Costs

4. Value of Affordable Housing

The October 2023 consultation proposed:

• Affordable Rented homes attribute a value of £1,735m2 (60% of affordable homes in total)

• And Affordable Home Ownership products attribute a value at 70% of the market value (40% of affordable homes in total)

The December 2024 report considered feedback but used assumptions that were unaltered, despite submitted evidence that actual values paid to developers by RP's were far lower.

This mismatch is due to several factors:

• Ormesby 7 homes for rent (2x1BF, 4x2BH, 1x3BH) plus 1x2BH for Shared Ownership. Sept 23, the highest offer having approached 8 RP's was £1,553m2

• Freethorpe 2 homes for rent (2x2BH) plus 1x3BH for Shared Ownership. December 2022, the highest offer having approached 8 RP's was £1,868m2

• Martham 10 homes for rent (5x1BB, 5X3BB), Plus 6 homes for Shared Ownership sale (2x1BB, 4x2BB). July 21, the highest offer having approached 8 RP's was £2,024m2

5. Conclusion

• Inadequate assumptions relating to external works costs

• Overly optimistic assumptions relating to the value of affordable housing

In addition, the revised NPPF removes the requirement for First Homes, which requires a response from the council which does not further damage viability.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP82-86 - Cripps Developments (Microsoft Excel, 23 KB)(opens new window)

Rep ID: 87 / Respondent: Pathfinder Development Consultants on behalf of Badger Building (E. Anglia) Ltd

Date Received: 1/13/2025

Section of the Plan: 0

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Local Plan Viability Assessment

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

We wish to make comment specifically on:

1. The Draft Local Plan is underpinned by: The Local Plan Viability Assessment.

Draft Local Plan Policies are: Supported and underpinned by:

• The Local Plan Viability Assessment - December 2023 undertaken by HDH

• Hou8 - Housing space standards (NDSS)

• Hou9 - Accessibility Standards: All new homes to comply with M4(2), 10% of affordable housing to be M4(3)

• BNG: NAT 3 - at 20% (rather than 10%)

• Nutrient Neutrality - Nat 5 (which was not tested in The Local Plan Viability Assessment)

2. Inadequacy of draft Viability Assessment

A draft Viability Assessment was sent out to consultation on the 9th October 2023.

3. External Works Costs

4. Value of Affordable Housing

The October 2023 consultation proposed:

• Affordable Rented homes attribute a value of £1,735m2 (60% of affordable homes in total)

• And Affordable Home Ownership products attribute a value at 70% of the market value (40% of affordable homes in total)

The December 2024 report considered feedback but used assumptions that were unaltered, despite submitted evidence that actual values paid to developers by RP's were far lower.

This mismatch is due to several factors:

• Ormesby 7 homes for rent (2x1BF, 4x2BH, 1x3BH) plus 1x2BH for Shared Ownership. Sept 23, the highest offer having approached 8 RP's was £1,553m2

• Freethorpe 2 homes for rent (2x2BH) plus 1x3BH for Shared Ownership. December 2022, the highest offer having approached 8 RP's was £1,868m2

• Martham 10 homes for rent (5x1BB, 5X3BB), Plus 6 homes for Shared Ownership sale (2x1BB, 4x2BB). July 21, the highest offer having approached 8 RP's was £2,024m2

5. Conclusion

• Inadequate assumptions relating to external works costs

• Overly optimistic assumptions relating to the value of affordable housing

In addition, the revised NPPF removes the requirement for First Homes, which requires a response from the council which does not further damage viability.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP87-91 - Badger Building (Microsoft Excel, 23 KB)(opens new window)

Rep ID: 88 / Respondent: Pathfinder Development Consultants on behalf of Badger Building (E. Anglia) Ltd

Date Received: 1/13/2025

Section of the Plan: 7

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HOU1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

We wish to make comment specifically on:

1. The Draft Local Plan is underpinned by: The Local Plan Viability Assessment.

Draft Local Plan Policies are: Supported and underpinned by:

• The Local Plan Viability Assessment - December 2023 undertaken by HDH

• Hou8 - Housing space standards (NDSS)

• Hou9 - Accessibility Standards: All new homes to comply with M4(2), 10% of affordable housing to be M4(3)

• BNG: NAT 3 - at 20% (rather than 10%)

• Nutrient Neutrality - Nat 5 (which was not tested in The Local Plan Viability Assessment)

2. Inadequacy of draft Viability Assessment

A draft Viability Assessment was sent out to consultation on the 9th October 2023.

3. External Works Costs

4. Value of Affordable Housing

The October 2023 consultation proposed:

• Affordable Rented homes attribute a value of £1,735m2 (60% of affordable homes in total)

• And Affordable Home Ownership products attribute a value at 70% of the market value (40% of affordable homes in total)

The December 2024 report considered feedback but used assumptions that were unaltered, despite submitted evidence that actual values paid to developers by RP's were far lower.

This mismatch is due to several factors:

• Ormesby 7 homes for rent (2x1BF, 4x2BH, 1x3BH) plus 1x2BH for Shared Ownership. Sept 23, the highest offer having approached 8 RP's was £1,553m2

• Freethorpe 2 homes for rent (2x2BH) plus 1x3BH for Shared Ownership. December 2022, the highest offer having approached 8 RP's was £1,868m2

• Martham 10 homes for rent (5x1BB, 5X3BB), Plus 6 homes for Shared Ownership sale (2x1BB, 4x2BB). July 21, the highest offer having approached 8 RP's was £2,024m2

5. Conclusion

• Inadequate assumptions relating to external works costs

• Overly optimistic assumptions relating to the value of affordable housing

In addition, the revised NPPF removes the requirement for First Homes, which requires a response from the council which does not further damage viability.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP87-91 - Badger Building (Microsoft Excel, 23 KB)(opens new window)

Rep ID: 89 / Respondent: Pathfinder Development Consultants on behalf of Badger Building (E. Anglia) Ltd

Date Received: 1/13/2025

Section of the Plan: 7

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HOU9

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

We wish to make comment specifically on:

1. The Draft Local Plan is underpinned by: The Local Plan Viability Assessment.

Draft Local Plan Policies are: Supported and underpinned by:

• The Local Plan Viability Assessment - December 2023 undertaken by HDH

• Hou8 - Housing space standards (NDSS)

• Hou9 - Accessibility Standards: All new homes to comply with M4(2), 10% of affordable housing to be M4(3)

• BNG: NAT 3 - at 20% (rather than 10%)

• Nutrient Neutrality - Nat 5 (which was not tested in The Local Plan Viability Assessment)

2. Inadequacy of draft Viability Assessment

A draft Viability Assessment was sent out to consultation on the 9th October 2023.

3. External Works Costs

4. Value of Affordable Housing

The October 2023 consultation proposed:

• Affordable Rented homes attribute a value of £1,735m2 (60% of affordable homes in total)

• And Affordable Home Ownership products attribute a value at 70% of the market value (40% of affordable homes in total)

The December 2024 report considered feedback but used assumptions that were unaltered, despite submitted evidence that actual values paid to developers by RP's were far lower.

This mismatch is due to several factors:

• Ormesby 7 homes for rent (2x1BF, 4x2BH, 1x3BH) plus 1x2BH for Shared Ownership. Sept 23, the highest offer having approached 8 RP's was £1,553m2

• Freethorpe 2 homes for rent (2x2BH) plus 1x3BH for Shared Ownership. December 2022, the highest offer having approached 8 RP's was £1,868m2

• Martham 10 homes for rent (5x1BB, 5X3BB), Plus 6 homes for Shared Ownership sale (2x1BB, 4x2BB). July 21, the highest offer having approached 8 RP's was £2,024m2

5. Conclusion

• Inadequate assumptions relating to external works costs

• Overly optimistic assumptions relating to the value of affordable housing

In addition, the revised NPPF removes the requirement for First Homes, which requires a response from the council which does not further damage viability.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP87-91 - Badger Building (Microsoft Excel, 23 KB)(opens new window)

Rep ID: 90 / Respondent: Pathfinder Development Consultants on behalf of Badger Building (E. Anglia) Ltd

Date Received: 1/13/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT3

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

We wish to make comment specifically on:

1. The Draft Local Plan is underpinned by: The Local Plan Viability Assessment.

Draft Local Plan Policies are: Supported and underpinned by:

• The Local Plan Viability Assessment - December 2023 undertaken by HDH

• Hou8 - Housing space standards (NDSS)

• Hou9 - Accessibility Standards: All new homes to comply with M4(2), 10% of affordable housing to be M4(3)

• BNG: NAT 3 - at 20% (rather than 10%)

• Nutrient Neutrality - Nat 5 (which was not tested in The Local Plan Viability Assessment)

2. Inadequacy of draft Viability Assessment

A draft Viability Assessment was sent out to consultation on the 9th October 2023.

3. External Works Costs

4. Value of Affordable Housing

The October 2023 consultation proposed:

• Affordable Rented homes attribute a value of £1,735m2 (60% of affordable homes in total)

• And Affordable Home Ownership products attribute a value at 70% of the market value (40% of affordable homes in total)

The December 2024 report considered feedback but used assumptions that were unaltered, despite submitted evidence that actual values paid to developers by RP's were far lower.

This mismatch is due to several factors:

• Ormesby 7 homes for rent (2x1BF, 4x2BH, 1x3BH) plus 1x2BH for Shared Ownership. Sept 23, the highest offer having approached 8 RP's was £1,553m2

• Freethorpe 2 homes for rent (2x2BH) plus 1x3BH for Shared Ownership. December 2022, the highest offer having approached 8 RP's was £1,868m2

• Martham 10 homes for rent (5x1BB, 5X3BB), Plus 6 homes for Shared Ownership sale (2x1BB, 4x2BB). July 21, the highest offer having approached 8 RP's was £2,024m2

5. Conclusion

• Inadequate assumptions relating to external works costs

• Overly optimistic assumptions relating to the value of affordable housing

In addition, the revised NPPF removes the requirement for First Homes, which requires a response from the council which does not further damage viability.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP87-91 - Badger Building (Microsoft Excel, 23 KB)(opens new window)

Rep ID: 91 / Respondent: Pathfinder Development Consultants on behalf of Badger Building (E. Anglia) Ltd

Date Received: 1/13/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT5

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

We wish to make comment specifically on:

1. The Draft Local Plan is underpinned by: The Local Plan Viability Assessment.

Draft Local Plan Policies are: Supported and underpinned by:

• The Local Plan Viability Assessment - December 2023 undertaken by HDH

• Hou8 - Housing space standards (NDSS)

• Hou9 - Accessibility Standards: All new homes to comply with M4(2), 10% of affordable housing to be M4(3)

• BNG: NAT 3 - at 20% (rather than 10%)

• Nutrient Neutrality - Nat 5 (which was not tested in The Local Plan Viability Assessment)

2. Inadequacy of draft Viability Assessment

A draft Viability Assessment was sent out to consultation on the 9th October 2023.

3. External Works Costs

4. Value of Affordable Housing

The October 2023 consultation proposed:

• Affordable Rented homes attribute a value of £1,735m2 (60% of affordable homes in total)

• And Affordable Home Ownership products attribute a value at 70% of the market value (40% of affordable homes in total)

The December 2024 report considered feedback but used assumptions that were unaltered, despite submitted evidence that actual values paid to developers by RP's were far lower.

This mismatch is due to several factors:

• Ormesby 7 homes for rent (2x1BF, 4x2BH, 1x3BH) plus 1x2BH for Shared Ownership. Sept 23, the highest offer having approached 8 RP's was £1,553m2

• Freethorpe 2 homes for rent (2x2BH) plus 1x3BH for Shared Ownership. December 2022, the highest offer having approached 8 RP's was £1,868m2

• Martham 10 homes for rent (5x1BB, 5X3BB), Plus 6 homes for Shared Ownership sale (2x1BB, 4x2BB). July 21, the highest offer having approached 8 RP's was £2,024m2

5. Conclusion

• Inadequate assumptions relating to external works costs

• Overly optimistic assumptions relating to the value of affordable housing

In addition, the revised NPPF removes the requirement for First Homes, which requires a response from the council which does not further damage viability.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP87-91 - Badger Building (Microsoft Excel, 23 KB)

Rep ID: 92 / Respondent: Norfolk Wildlife Trust

Date Received: 1/21/2025

Section of the Plan: 2

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:2.2

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: We repeat our previous comment that to be effective, we recommend that the text around net zero is quantified to provide a measurable and deliverable target. The current text 'well on the way' to net zero is very vague.

The vision is completely lacking in any mention of nature or biodiversity. In order to be consistent with achieving sustainable development, we recommend additional text is added to the overall vision detailing the aspirations for the enhancement of biodiversity. We suggest the following sentence be added:

In line with national targets set by the Environment Act, nature within the borough is clearly on the pathway to recovery; biodiversity will be enhanced and the condition of internationally, nationally and locally protected habitats and sites will have been improved

Suggested Modifications: we recommend that the text around net zero is quantified to provide a measurable and deliverable target. The current text 'well on the way' to net zero is very vague.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Date Received: 1/21/2025

Section of the Plan: 11

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy TCL1 11.4

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Paragraph 11.4 - In order to be consistent with achieving sustainable development, we repeat our recommendation to strengthen the wording of 'must have regard to Policies NAT6, NAT7, NAT8 and NAT9'. We also recommend referencing NAT1 and NAT2 policies here. We suggest the following wording:

"The Borough also comprises areas of the Broads network and other important landscapes where development must comply with, where relevant, to Policies NAT1, NAT2, NAT6, NAT7, NAT8 and NAT9".

Suggested Modifications: Paragraph 11.4 - In order to be consistent with achieving sustainable development, we repeat our recommendation to strengthen the wording of 'must have regard to Policies NAT6, NAT7, NAT8 and NAT9'. We also recommend referencing NAT1 and NAT2 policies here. We suggest the following wording:

"The Borough also comprises areas of the Broads network and other important landscapes where development must comply with, where relevant, to Policies NAT1, NAT2, NAT6, NAT7, NAT8 and NAT9".

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 99 / Respondent: Norfolk Wildlife Trust

Date Received: 1/21/2025

Section of the Plan: 12

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HEC6

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: We support this policy.

Suggested Modifications: None

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 100 / Respondent: Norfolk Wildlife Trust

Date Received: 1/21/2025

Section of the Plan: 14

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CLC6

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: We repeat our recommendation to strengthen wording of this policy from 'encouraged', in order to be consistent with achieving sustainable development. Given the need to tackle the scale of the climate crisis we recommend that faster progress towards net zero is required, in line with the weight afforded to the measures in the updated NPPF (Paragraph 164): In determining planning applications, local planning authorities should give significant weight to the need to support energy efficiency and low carbon heating improvements to existing buildings, both domestic and non-domestic (including through installation of heat pumps and solar panels where these do not already benefit from permitted development rights).

Suggested Modifications: We recommend that the supporting text in paragraph 14.68 is removed - "The policy is an encouragement policy in that development will not be refused if does not incorporate the desires of the policy, however, weight will be given in favour of proposals which do go beyond the building regulations in line with the policy." In order to be consistent with achieving sustainable development, we recommend that the same stance is taken as that in CLC8 which only permits new development if it meets the highest standards.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 101 / Respondent: Norfolk Wildlife Trust

Date Received: 1/21/2025

Section of the Plan: 15

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy DHE1

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: We support this policy around sustainable design. However, in order to be consistent with achieving sustainable development, we repeat our recommendation that an additional clause is added to cover embodied carbon. We suggest the following text:

Development proposals should calculate whole life-cycle carbon emissions through a nationally recognised Whole Life-Cycle Carbon Assessment and demonstrate actions taken to reduce life-cycle carbon emissions.

Operational carbon emissions make up a declining percentage of a development's whole life-cycle carbon emissions as operational carbon targets become more stringent. To fully capture a development's carbon impact, a whole life-cycle approach is needed. Whole life-cycle carbon emission assessments are therefore required. The approach to whole life-cycle carbon emissions assessments, including when they should take place, what they should contain and how information should be reported, should be set out in the design code.

Suggested Modifications: We support this policy around sustainable design. However, in order to be consistent with achieving sustainable development, we repeat our recommendation that an additional clause is added to cover embodied carbon. We suggest the following text:

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 102 / Respondent: Norfolk Wildlife Trust

Date Received: 1/21/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: We support inclusion of additional wording to include SSSIs, which are nationally protected sites. We repeat our recommendation relating to the third paragraph of the policy which accounts for "other biodiversity and geodiversity assets" and suggest that priority species and habitats are noted.

Suggested Modifications: We support inclusion of additional wording to include SSSIs, which are nationally protected sites. We repeat our recommendation relating to the third paragraph of the policy which accounts for "other biodiversity and geodiversity assets" and suggest that priority species and habitats are noted.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 103 / Respondent: Norfolk Wildlife Trust

Date Received: 1/21/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:16.5

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: We support the supporting text to this policy in paragraphs 16.5 outlining the need to follow the mitigation hierarchy.

Suggested Modifications: None

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 104 / Respondent: Norfolk Wildlife Trust

Date Received: 1/21/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:16.6

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: We support the supporting text in 16.6 around installation of bat boxes/bird boxes. We recommend that this could be strengthened by altering the text from 'encouraged' to 'must'

Suggested Modifications: We support the supporting text in 16.6 around installation of bat boxes/bird boxes. We recommend that this could be strengthened by altering the text from 'encouraged' to 'must'

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 105 / Respondent: Norfolk Wildlife Trust

Date Received: 1/21/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT3

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: We strongly support the Council's target of 20% BNG for all major development, outside of the exceptions listed.

Suggested Modifications:

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 106 / Respondent: Norfolk Wildlife Trust

Date Received: 1/21/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT5

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: In order to ensure that run-off impacts on the water quality of the Broads SAC (in particular relating to the Trinity Broads area of the SAC), we recommend a specific policy requirement for the assessment of run-off impacts on the water quality of the Broads from any new built development close to the water's edge, either from new allocations or speculative development

Suggested Modifications: In order to ensure that run-off impacts on the water quality of the Broads SAC (in particular relating to the Trinity Broads area of the SAC), we recommend a specific policy requirement for the assessment of run-off impacts on the water quality of the Broads from any new built development close to the water's edge, either from new allocations or speculative development

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 107 / Respondent: Norfolk Wildlife Trust

Date Received: 1/21/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT9

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: We repeat our recommendation that the last paragraph should include a reference to having no adverse effects on wildlife. We support the text in paragraph 16.59.

We also recommend including the following:

'All development proposals should demonstrate compliance with best practice guidance for avoiding artificial lighting impacts on bats:

(https://theilp.org.uk/publication/guidance-note-8-bats-and-artificial-lighting/ ).

Where applications are adjacent to or near to designated wildlife sites or Priority Habitats then they must be designed to avoid light spill onto wildlife roosts, foraging habitat, and commuting routes for bats, birds and other species.'

Suggested Modifications: We repeat our recommendation that the last paragraph should include a reference to having no adverse effects on wildlife. We support the text in paragraph 16.59.

We also recommend including the following:

'All development proposals should demonstrate compliance with best practice guidance for avoiding artificial lighting impacts on bats:

(https://theilp.org.uk/publication/guidance-note-8-bats-and-artificial-lighting/ ).

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 108 / Respondent: Norfolk Wildlife Trust

Date Received: 1/21/2025

Section of the Plan: 0

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Appendix 1 Design Code

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Appendix 1. Design code

Addressing climate change and conserving resources

In order to be consistent with achieving sustainable development, we repeat our previous recommendation that an additional section is included around the issue of embodied carbon. As building standards and regulations start to reduce the operational emissions from buildings, embodied carbon emissions can make up as much as 50% of total emissions over a building's lifetime2. We recommend that requirements are set for all new homes as follows:

• All developments shall demonstrate actions taken to reduce embodied carbon and maximise opportunities for re-use through the provision of a circular economy statement.

• Major developments (defined as those with 10 or more dwellings or 1,000 square metres of floorspace) should calculate whole-lifecycle carbon emissions (including embodied carbon emissions) through a nationally recognised whole-lifecycle carbon methodology and should demonstrate actions taken to reduce lifecycle carbon emissions.

• Performance changes should be monitored through updated as-designed and as-built embodied carbon assessments. Developments should not only measure performance, but also submit whole-lifecycle data to public databases (such as the Built Environment Carbon Database).

CC3: Integrate on-site renewable energy generation and low zero carbon cooling and ventilation systems

We support the intention of these guidelines but in order to be consistent with achieving sustainable development, given the need to tackle the scale of the climate crisis we recommend that faster progress towards net zero is required. We recommend that this section is strengthened and that the outcomes are made 'expected outcomes' rather than 'best practise outcomes'.

CC4: Minimise potable water use

In order to be consistent with achieving sustainable development, we recommend that this is made an 'expected outcome' rather than 'best practise'. Water efficiency supports both climate change mitigation and adaptation, as heating water can increase energy use (which may have a carbon impact depending on the heating system), and pressure on water availability will increase as a result of climate change. The design of new developments should optimise the inclusion of water efficiency and consumption measures, such as rainwater/ or greywater recycling, low flow taps and showers, low flush toilets, rain gardens and water butts and Sustainable Urban Drainage Systems (SUDS) in the construction of new buildings. All major non-residential development should incorporate water conservation measures to achieve full credits for category Wat 01 of BREEAM.

CC8: Minimise resource usage through future building maintenance, alterations and adaptation

In order to be consistent with achieving sustainable development, we recommend that this section is strengthened and that the outcomes are made 'expected outcomes' rather than 'best practise outcomes'.

PS2: Provide a sufficient quantity, type, and quality, of public open space and green infrastructure with development

In order to be consistent with achieving sustainable development , we recommend that the 'best practice outcome' to Meet the urban greening factors set out in Natural England's Green Infrastructure Standards of 0.3 for commercial development, 0.4 for residential brownfield development and 0.5 for residential greenfield development be made 'expected outcome'.

We strongly recommend that for urban areas in the Borough, the Urban Greening Factor is applied as policy, as a means of effectively delivering multiple environmental benefits for wildlife, climate change and residents' quality of life through new development.

We believe that new development can provide valuable opportunities to incorporate wildlife, providing benefits not only for declining wildlife species but also improving quality of life of residents through greater daily interaction with wildlife, as well as making important contributions to reducing rainwater run-off, and mitigating climate change impacts through providing greater insulation for buildings and reducing the urban heat island effect. We recommend that the Council reviews the recommendations of Natural England's recently released Green Infrastructure Framework:

https://designatedsites.naturalengland.org.uk/GreenInfrastructure/Home.aspx, which sets out best practice aspirations for green infrastructure delivery, including guidance on Process Journeys for Local Authorities: https://designatedsites.naturalengland.org.uk/GreenInfrastructure/ProcessJourneys.aspx."

Suggested Modifications: Appendix 1. Design code

Addressing climate change and conserving resources

• All developments shall demonstrate actions taken to reduce embodied carbon and maximise opportunities for re-use through the provision of a circular economy statement.

CC3: Integrate on-site renewable energy generation and low zero carbon cooling and ventilation systems

CC4: Minimise potable water use

CC8: Minimise resource usage through future building maintenance, alterations and adaptation

PS2: Provide a sufficient quantity, type, and quality, of public open space and green infrastructure with development

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 109 / Respondent: Robin Wilkinson

Date Received: 1/15/2025

Section of the Plan: 5

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CAS1

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Does not comply with Duty to Co-operate

Reasons: Nobody listens to the people of Caister-on-Sea

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 110 / Respondent: Alan Walker

Date Received: 1/15/2025

Section of the Plan: 0

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policies Map

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Does not comply with Duty to Co-operate

Reasons: No basic infrastructure and the existing is already overloaded.

Suggested Modifications: Just retain the current 660 houses currently under construction.

Request to be heard?: Yes

Reason for Request to be heard:I feel like we as a community are being forced into this flagrant expansion

Attachments: N/A

Rep ID: 111 / Respondent: Jacqueline Walker

Date Received: 1/15/2025

Section of the Plan: 0

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policies Map

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Does not comply with Duty to Co-operate

Reasons: There is no established infrastructure to support this build. Space allocated does not result in established infrastructure. No provision for adequate sewerage treatment etc. The list goes on..... medical centres......not factual but fully planned and staffed.

Suggested Modifications: You need to provide a revised plan of action to ensure that the people of Caister receive the facilities and infrastructure they deserve. We don't have a say in our village anymore.

Request to be heard?: Yes

Reason for Request to be heard:I wish to know what is going on in our village. The right of opinion has been taken away from us!

Attachments: N/A

Rep ID: 112 / Respondent: Historic England

Date Received: 1/23/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB2

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: While we welcome the inclusion of numerous references to the historic environment within Policy URB2 and its supporting text, and in particular the recognition that regeneration of the town centre presents an opportunity to restore heritage, we suggest amending criterion 'e' to align more closely with the language used in the NPPF.

Suggested Modifications: Recommendation: Amend criteria 'e' to read: conserve and enhance the town centre's rich variety of heritage historic assets...

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments:

112-126 240123 HE Response (PDF, 1 MB)(opens new window)

112-126 Email confirmation - Historic England (PDF, 1 MB)(opens new window)

Rep ID: 113 / Respondent: Historic England

Date Received: 1/23/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB4

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: The area occupies a large and prominent location on the waterfront and includes the arrival point to the historic town from the railway station to the north and is close to that to the south from the A12 over Bridge Road. The site incorporates the conservation areas of St Nicholas/Northgate Street and Market Place, Rows and North Quay and two listed buildings and lies within the setting of other listed buildings and Hall and South Quay conservation area.

Historic England recognises the opportunity the area presents for the regeneration of Great Yarmouth and the potential this offers to enhance the significance of the conservation areas and, through sensitive and appropriately scaled new development, bring vibrancy to the area and wider town. To ensure that development is planned and delivered appropriately, we have previously recommended that a Heritage Impact Assessment (HIA) be prepared to demonstrate how the proposed numbers and densities could be achieved while conserving and enhancing the historic environment, in line with national planning policy.

We therefore welcome the Council's HIA. While we generally support the policy and its supporting text, we consider that its efficacy, and therefore its soundness, could be improved through the following amendments:

Suggested Modifications: Criterion 'd'

Criterion 'd' states that development should exhibit exceptional urban design. While we agree with this requirement, we recommend that it be amended to specify that the design should also be contextual. This would ensure that development is informed by, and responds appropriately to, its surrounding context, including the wider historic environment.

Criterion 'g'

Criterion 'g' states: "The design and layout of development will need to conserve and enhance the character and setting of listed buildings located within the site and those adjacent..."

We are concerned that the use of the term "adjacent" implies only those listed buildings located next to, or within the immediate vicinity of the site. This would exclude long views to key heritage assets, such as the grade II* listed Church of St Nicholas (the Minster) (LEN 1096813) and grade II* listed Town Hall (LEN 1246969), which are integral to the historic environment and should be considered in the assessment of character and setting.

We recommend revising the wording to ensure that the conservation and enhancement of all relevant listed buildings, including those visible in long views, are appropriately addressed.

In addition, Criterion 'g' states: "...There is a presumption in retaining and reusing listed buildings, scheduled monuments, and locally historic buildings that hold significance within the Conservation Area."

We believe that Criterion 'g' should set a higher standard for the historic environment. Specifically, we recommend removing the qualifying phrase "there is a presumption" to strengthen the requirement. The criterion would then read:

"Listed buildings, scheduled monuments, and locally historic buildings that hold significance within the Conservation Area should be retained and reused."

Finally, while we welcome the requirement for a scheme specific Heritage Impact Assessment, we believe this could be strengthened by clarifying its purpose, the expected timescales for its preparation, and its critical role in shaping site specific proposals. To provide greater clarity and ensure its effectiveness (and therefore soundness), we recommend revising the final sentence of Criterion 'g' to read:

Specific enhancement and mitigation measures will be identified through the preparation of a further detailed/scheme specific Heritage Impact Assessment which will inform and be submitted prior to the determination of with any application at the site.

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments:

112-126 240123 HE Response (PDF, 1 MB)(opens new window)

112-126 Email confirmation - Historic England (PDF, 1 MB)(opens new window)

Rep ID: 114 / Respondent: Historic England

Date Received: 1/23/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB9

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: This site includes the Grade II listed Gasholder Number 172 at former Great Yarmouth Gasworks (LEN 1096789). The Great Yarmouth gas holder survives as an evocative example of how energy was provided during the 19th century and for a large part of the 20th century. It dates from 1884 and is the last surviving above ground component of the town gas works.

We're pleased to see the Council's Heritage Impact Assessment (HIA) and the amendments to the Policy and supporting text following our recommendations at Regulation 18. However, we believe the Policy could be further strengthened by clarifying the purpose, timescales, and critical role of the scheme specific HIA in shaping site specific proposals.

Suggested Modifications: To provide greater clarity and ensure its effectiveness (and therefore soundness), we recommend revising the second sentence of Criterion 'd' to read:

Recommendation: Specific enhancement and mitigation measures will be identified through the preparation of a scheme specific Heritage Impact Assessment, which will assess the impact of the development on the setting of the Gasholder and other designated heritage assets, including the Grade II listed Dolphin Public House. This assessment will be submitted prior to the determination of any application for the site.

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments:

112-126 240123 HE Response (PDF, 1 MB)(opens new window)

112-126 Email confirmation - Historic England (PDF, 1 MB)(opens new window)

Rep ID: 115 / Respondent: Historic England

Date Received: 1/23/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB12

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: We welcome the inclusion of policy criteria 'm' and supporting text regarding the conservation of Great Yarmouth's historic seafront. The specific mention of the Grade II* Winter Gardens is welcomed. However, we suggest the supporting text could be improved by identifying additional designated heritage assets within the Policy URB12 area, such as the Grade II listed Empire Cinema, the Royal Hotel, and the Maritime Museum etc.

Suggested Modifications: Recommendation: The supporting text could be improved by referring to other designated heritage assets within the red-line area.

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments:

112-126 240123 HE Response (PDF, 1 MB)(opens new window)

112-126 Email confirmation - Historic England (PDF, 1 MB)(opens new window)

Rep ID: 116 / Respondent: Historic England

Date Received: 1/23/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB26

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: The site is adjacent to Church Farmhouse (grade II listed) and the Barn at Church Farmhouse (also grade II listed). We therefore welcome Criterion 'e,' which specifies that development proposals must be informed by an appropriate landscaping scheme to mitigate impacts on the wider landscape and enhance the setting of adjacent heritage assets.

Suggested Modifications: None

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments:

112-126 240123 HE Response (PDF, 1 MB)(opens new window)

112-126 Email confirmation - Historic England (PDF, 1 MB)(opens new window)

Rep ID: 117 / Respondent: Historic England

Date Received: 1/23/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy MAR6

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: The site is situated within the setting of the grade II listed 'Pair of Attached Barns at Moregrove Farm.' We therefore welcome Criterion 'g,' which requires development proposals to be informed by a Heritage Impact Assessment and an archaeological field evaluation, including trial trenching, conducted by a suitably qualified person. This should include any necessary mitigation measures, which must be clearly set out and implemented. However, we are concerned that supporting text in paragraph 6.224 suggests the primary focus of this assessment will be to understand the significance of any non-designated archaeological remains on site and how these will be addressed through the development. This approach overlooks the potential impact of the development on the grade II listed 'Pair of Attached Barns at Moregrove Farm' through changes to their setting.

Suggested Modifications: Recommendation:

We recommend that paragraph 6.224 be amended to explicitly reference the 'Pair of Attached Barns at Moregrove Farm' and to clarify that proposals will be expected to incorporate any necessary mitigation and enhancement measures identified through the Heritage Impact Assessment to protect its setting

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments:

112-126 240123 HE Response (PDF, 1 MB)(opens new window)

112-126 Email confirmation - Historic England (PDF, 1 MB)(opens new window)

Rep ID: 118 / Respondent: Historic England

Date Received: 1/23/2025

Section of the Plan: 5

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CAS1

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: We previously raised concerns about the potential allocation of this site, which lies within the wider setting of the Scheduled Monument and grade I listed Caister Castle, as well as the non-designated WWII gun battery at Nova Scotia Farm. Our primary concern was the potential impact on Caister Castle through changes to its setting, particularly the effect of development on views from the castle tower, which offers commanding and extensive views across the landscape.

We therefore welcome the Council's Heritage Impact Assessment and the amendments made to the Policy and supporting text following our recommendations at Regulation 18. In particular, we are pleased to see Criterion 'h,' which requires space and planting along the southern boundary to conserve the setting of Caister Castle. It is also reassuring that Criterion 'i' specifies the retention of the WWII gun battery and the need to maintain open space in front of it.

Finally, we are particularly pleased with Criterion 'j,' which introduces a requirement for a scheme specific Heritage Impact Assessment. This criterion clearly outlines the purpose of the assessment, the expected timescales for its preparation, and its critical role in shaping site specific proposals (see our related comments on URB4 and URB9).

Suggested Modifications: Recommendation: None.

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments:

112-126 240123 HE Response (PDF, 1 MB)(opens new window)

112-126 Email confirmation - Historic England (PDF, 1 MB)(opens new window)

Rep ID: 119 / Respondent: Historic England

Date Received: 1/23/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy MAR3

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: The site is located immediately to the west of the grade II listed 'Old Hall Farmhouse.' We have previously expressed concerns about the potential allocation of this site due to the risk of development impacting the significance of this designated heritage asset by altering its agricultural setting. Ideally, a Heritage Impact Assessment (HIA) should have been undertaken prior to the preparation of this Regulation 19 draft to ensure that any recommendations for mitigation and enhancement could inform and shape Policy MAR3.

We are disappointed that no further assessment of the potential impact on the significance of these assets has been carried out at this stage. However, we note and welcome Criterion 'e' of the policy, which requires the submission of a landscape strategy and Heritage Impact Assessment to ensure that the setting of the grade II listed Old Hall Farmhouse is preserved. While we would have preferred this work to have been completed earlier, we consider that, on this occasion, the policy criteria provide sufficient safeguards to address the potential impacts on the historic environment.

Suggested Modifications: Recommendation: None.

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments:

112-126 240123 HE Response (PDF, 1 MB)(opens new window)

112-126 Email confirmation - Historic England (PDF, 1 MB)(opens new window)

Rep ID: 120 / Respondent: Historic England

Date Received: 1/23/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy ORM3

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: We have previously raised concerns regarding the potential allocation of ORM3, on the basis that development is potentially within the setting of several listed buildings and structures, including Ormesby Old Hall (grade II * listed), Old Hall Cottage (grade II listed), Stable and Forecourt walls to Ormesby Old Hall (grade II listed), and Church of St Margaret (grade II * listed), as well as the Ormesby St Margaret Conservation Area.

Ideally, a Heritage Impact Assessment (HIA) should have been undertaken prior to the preparation of this Regulation 19 draft to ensure that any recommendations for mitigation and enhancement could inform and shape Policy ORM3. We are disappointed that no such assessment has been completed at this stage.

However, we welcome the inclusion of Criterion 'g' within the policy, which requires the submission of a Heritage Impact Assessment to demonstrate that any negative impacts on the significance of the heritage setting have been avoided, or, if this is not possible, mitigated. While it would have been preferable for this work to have been completed earlier, we consider that, on this occasion, the policy criteria provide sufficient safeguards to address potential impacts on the historic environment.

Suggested Modifications: Recommendation: None.

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments:

112-126 240123 HE Response (PDF, 1 MB)(opens new window)

112-126 Email confirmation - Historic England (PDF, 1 MB)(opens new window)

Rep ID: 121 / Respondent: Historic England

Date Received: 1/23/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy REP1

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: The site is located adjacent to the Church of St Peter and St Paul (grade II* listed and identified as a Heritage at Risk) and the Repps with Bastwick War Memorial (grade II listed). We note and welcome the requirement for potential impacts on the setting of heritage assets to be assessed through a Heritage Impact Assessment (HIA).

We are particularly pleased to see the inclusion of supporting text (6.238) following our feedback to the Council's Regulation 18 consultation. This text makes it clear that proposals will be expected to seek opportunities to enhance the Heritage at Risk Church of St Peter and St Paul.

Suggested Modifications: Recommendation: None.

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments:

112-126 240123 HE Response (PDF, 1 MB)(opens new window)

112-126 Email confirmation - Historic England (PDF, 1 MB)(opens new window)

Rep ID: 122 / Respondent: Historic England

Date Received: 1/23/2025

Section of the Plan: 15

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy DHE1

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Noted.

Suggested Modifications: -

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments:

112-126 240123 HE Response (PDF, 1 MB)(opens new window)

112-126 Email confirmation - Historic England (PDF, 1 MB)(opens new window)

Rep ID: 123 / Respondent: Historic England

Date Received: 1/23/2025

Section of the Plan: 15

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy DHE2

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: We welcome and support policy DEH2 which is bespoke, and Great Yarmouth specific. We particularly welcome the support to proposals which enable the conservation of assets on the heritage at risk register.

While we are pleased to see that Great Yarmouth Minster, the Former Gasholder, and Britannia Monument are recognised as major landmark buildings and structures in the town and afforded a degree of protection under this policy, we are concerned that this intention is undermined by the phrase "significantly harm." Specifically, the wording: "Development proposals... will be supported... that does not significantly harm the strategic views of the asset" introduces ambiguity.

Suggested Modifications: Recommendation:

We suggest revising this phrasing to read: "Development proposals within sight of the following heritage assets will be supported where they enhance or give rise to improved views..."

This amendment would provide a clearer, more positive, and proactive approach to safeguarding and enhancing the views of these significant heritage assets

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments:

112-126 240123 HE Response (PDF, 1 MB)(opens new window)

112-126 Email confirmation - Historic England (PDF, 1 MB)(opens new window)

Rep ID: 124 / Respondent: Historic England

Date Received: 1/23/2025

Section of the Plan: 15

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy DHE3

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: We welcome the inclusion of non-designated parks and gardens in the policy following our feedback to the Council's Regulation 18 consultation.

Suggested Modifications: Recommendation: None.

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments:

112-126 240123 HE Response (PDF, 1 MB)(opens new window)

112-126 Email confirmation - Historic England (PDF, 1 MB)(opens new window)

Rep ID: 125 / Respondent: Historic England

Date Received: 1/23/2025

Section of the Plan: 15

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy DHE4

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Noted.

Suggested Modifications: None.

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments:

112-126 240123 HE Response (PDF, 1 MB)(opens new window)

112-126 Email confirmation - Historic England (PDF, 1 MB)(opens new window)

Rep ID: 126 / Respondent: Historic England

Date Received: 1/23/2025

Section of the Plan: 15

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy DHE5

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Noted.

Suggested Modifications: -

Request to be heard?: No

Reason for Request to be heard:N/A

Attachments:

112-126 240123 HE Response (PDF, 1 MB)(opens new window)

112-126 Email confirmation - Historic England (PDF, 1 MB)(opens new window)

Rep ID: 127 / Respondent: Baytree Surveying on behalf of Crocus Homes Ltd

Date Received: 1/13/2025

Section of the Plan: 7

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HOU8

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

We wish to make comment specifically on:

1. The Draft Local Plan is underpinned by: The Local Plan Viability Assessment.

Draft Local Plan Policies are: Supported and underpinned by:

• The Local Plan Viability Assessment - December 2023 undertaken by HDH

• Hou8 - Housing space standards (NDSS)

• Hou9 - Accessibility Standards: All new homes to comply with M4(2), 10% of affordable housing to be M4(3)

• BNG: NAT 3 - at 20% (rather than 10%)

• Nutrient Neutrality - Nat 5 (which was not tested in The Local Plan Viability Assessment)

2. Inadequacy of draft Viability Assessment

A draft Viability Assessment was sent out to consultation on the 9th October 2023.

3. External Works Costs

4. Value of Affordable Housing

The October 2023 consultation proposed:

• Affordable Rented homes attribute a value of £1,735m2 (60% of affordable homes in total)

• And Affordable Home Ownership products attribute a value at 70% of the market value (40% of affordable homes in total)

The December 2024 report considered feedback but used assumptions that were unaltered, despite submitted evidence that actual values paid to developers by RP's were far lower.

This mismatch is due to several factors:

• Ormesby 7 homes for rent (2x1BF, 4x2BH, 1x3BH) plus 1x2BH for Shared Ownership. Sept 23, the highest offer having approached 8 RP's was £1,553m2

• Freethorpe 2 homes for rent (2x2BH) plus 1x3BH for Shared Ownership. December 2022, the highest offer having approached 8 RP's was £1,868m2

• Martham 10 homes for rent (5x1BB, 5X3BB), Plus 6 homes for Shared Ownership sale (2x1BB, 4x2BB). July 21, the highest offer having approached 8 RP's was £2,024m2

5. Conclusion

• Inadequate assumptions relating to external works costs

• Overly optimistic assumptions relating to the value of affordable housing

In addition, the revised NPPF removes the requirement for First Homes, which requires a response from the council which does not further damage viability.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP77-81 - Crocus Homes (Microsoft Excel, 23 KB)(opens new window)

Rep ID: 128 / Respondent: Pathfinder Development Consultants on behalf of Cripps Developments

Date Received: 1/13/2025

Section of the Plan: 7

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HOU8

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: I have been appointed to make representations relating to the above Regulation 19 Submission of the Great Yarmouth Local Plan on behalf of my client Cripps Developments Ltd who are promoting a number of sites within the borough. I am a Chartered Surveyor with over 35 years post qualification experience specialising in the delivery of affordable housing, within the eastern region, working as a director of Pathfinder. Pathfinder are a consultancy offering services that assist in the delivery of affordable housing, site identification and appraisal, and in land acquisition. Our clients include national and regional house builders, as well as local developers, and land promotion organizations, individual landowners, Registered Providers and Local Authorities.

We wish to make comment specifically on:

1. The Draft Local Plan is underpinned by: The Local Plan Viability Assessment.

Draft Local Plan Policies are: Supported and underpinned by:

• The Local Plan Viability Assessment - December 2023 undertaken by HDH

• Hou8 - Housing space standards (NDSS)

• Hou9 - Accessibility Standards: All new homes to comply with M4(2), 10% of affordable housing to be M4(3)

• BNG: NAT 3 - at 20% (rather than 10%)

• Nutrient Neutrality - Nat 5 (which was not tested in The Local Plan Viability Assessment)

2. Inadequacy of draft Viability Assessment

A draft Viability Assessment was sent out to consultation on the 9th October 2023.

3. External Works Costs

4. Value of Affordable Housing

The October 2023 consultation proposed:

• Affordable Rented homes attribute a value of £1,735m2 (60% of affordable homes in total)

• And Affordable Home Ownership products attribute a value at 70% of the market value (40% of affordable homes in total)

The December 2024 report considered feedback but used assumptions that were unaltered, despite submitted evidence that actual values paid to developers by RP's were far lower.

This mismatch is due to several factors:

• Ormesby 7 homes for rent (2x1BF, 4x2BH, 1x3BH) plus 1x2BH for Shared Ownership. Sept 23, the highest offer having approached 8 RP's was £1,553m2

• Freethorpe 2 homes for rent (2x2BH) plus 1x3BH for Shared Ownership. December 2022, the highest offer having approached 8 RP's was £1,868m2

• Martham 10 homes for rent (5x1BB, 5X3BB), Plus 6 homes for Shared Ownership sale (2x1BB, 4x2BB). July 21, the highest offer having approached 8 RP's was £2,024m2

5. Conclusion

• Inadequate assumptions relating to external works costs

• Overly optimistic assumptions relating to the value of affordable housing

In addition, the revised NPPF removes the requirement for First Homes, which requires a response from the council which does not further damage viability.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP82-86 - Cripps Developments (Microsoft Excel, 23 KB)(opens new window)

Rep ID: 129 / Respondent: Pathfinder Development Consultants on behalf of Badger Building (E. Anglia) Ltd

Date Received: 1/13/2025

Section of the Plan: 7

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HOU8

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: I have been appointed to make representations relating to the above Regulation 19 Submission of the Great Yarmouth Local Plan on behalf of my client Badger Building (East Anglia) Limited, who are promoting a number of sites within the borough. I am a Chartered Surveyor with over 35 years post qualification experience specialising in the delivery of affordable housing, within the eastern region, working as a director of Pathfinder. Pathfinder are a consultancy offering services that assist in the delivery of affordable housing, site identification and appraisal, and in land acquisition. Our clients include national and regional house builders, as well as local developers, and land promotion organizations, individual landowners, Registered Providers and Local Authorities.

We wish to make comment specifically on:

1. The Draft Local Plan is underpinned by: The Local Plan Viability Assessment.

Draft Local Plan Policies are: Supported and underpinned by:

• The Local Plan Viability Assessment - December 2023 undertaken by HDH

• Hou8 - Housing space standards (NDSS)

• Hou9 - Accessibility Standards: All new homes to comply with M4(2), 10% of affordable housing to be M4(3)

• BNG: NAT 3 - at 20% (rather than 10%)

• Nutrient Neutrality - Nat 5 (which was not tested in The Local Plan Viability Assessment)

2. Inadequacy of draft Viability Assessment

A draft Viability Assessment was sent out to consultation on the 9th October 2023.

3. External Works Costs

4. Value of Affordable Housing

The October 2023 consultation proposed:

• Affordable Rented homes attribute a value of £1,735m2 (60% of affordable homes in total)

• And Affordable Home Ownership products attribute a value at 70% of the market value (40% of affordable homes in total)

The December 2024 report considered feedback but used assumptions that were unaltered, despite submitted evidence that actual values paid to developers by RP's were far lower.

This mismatch is due to several factors:

• Ormesby 7 homes for rent (2x1BF, 4x2BH, 1x3BH) plus 1x2BH for Shared Ownership. Sept 23, the highest offer having approached 8 RP's was £1,553m2

• Freethorpe 2 homes for rent (2x2BH) plus 1x3BH for Shared Ownership. December 2022, the highest offer having approached 8 RP's was £1,868m2

• Martham 10 homes for rent (5x1BB, 5X3BB), Plus 6 homes for Shared Ownership sale (2x1BB, 4x2BB). July 21, the highest offer having approached 8 RP's was £2,024m2

5. Conclusion

• Inadequate assumptions relating to external works costs

• Overly optimistic assumptions relating to the value of affordable housing

In addition, the revised NPPF removes the requirement for First Homes, which requires a response from the council which does not further damage viability.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP87-91 - Badger Building (Microsoft Excel, 23 KB)(opens new window)

Rep ID: 130 / Respondent: Caroline Beard

Date Received: 1/24/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Bradwell

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Does not comply with Duty to Co-operate

Reasons: Bluebell Meadow, Bradwell: Crime has increased since population increased due to overbuilding The roads are inadequate to cope with traffic volume. There is now a concern that adjacent to Jews Lane an area prone to flooding will be built upon. Given increasing problems with climate change, to build on an area that can be prone to flooding is unthinkable and will likely impact on dwellings that are already established. Also , ccording to Natural England reports of 2014, a number of species of bats live in Jews Lane. I have seen the bats use the flood plain and field for food and water. The protected Norfolk Darter uses the water as do other species of dragonflies, damselflies, butterflies and a variety of birds, some protected have used the flood plain. At the very least there should be an update survey done on the ecology of the area. There is also a discussion to reduce the amount of green space in this area to allow for more houses. The amount of new building on green land is affecting air quality and also the lack of infrastructure is appalling.

Suggested Modifications: I object to further building in Bradwell. As stated above. Also to build on recreational ground such as Meadow Park, adjacent to the A143 in Gorleston is insane. More people moving into the areas and yet lack of green areas to benefit from.

Request to be heard?: Yes

Reason for Request to be heard:I feel strongly about the environment in which I live. The amount of building in my area is appalling and has affected air quality and wildlife. With Climate change whicj should be of a major concern and yet buildings create carbon whilst green spaces ab

Attachments: N/A

Rep ID: 131 / Respondent: Philip Smith

Date Received: 1/24/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB21 4.205

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: The previous planning application has been scrapped by GYBC. My understanding is that National Highways stated that the road (A47 and Links road) would not cope with the considerable amount of traffic generated by the proposal and they would not be adding a new roundabout.

So, I fail to see why this new local plan continues to seek a huge development using a road (Links road) with two entry/exit points so near to an already, very busy roundabout.

The estate of Mariners Compass, which is opposite the proposed site, has two entry/exit points at each end of the estate , so it begs the question - why is Links road being treated differently?

I have no objection to the development of the site but the infrastructure of such a project must ensure that traffic flow is maintained and more importantly , the safety of road users of upheld . This proposed project appears to be to the detriment of road users

Suggested Modifications: It was suggested that the development should be served off a new roundabout off the A47 as a matter of safety and to reduce congestion.

Request to be heard?: Yes

Reason for Request to be heard:So that the inspector an get a balanced view

Attachments: N/A

Rep ID: 132 / Respondent: Robin Knight

Date Received: 1/24/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB25

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Does not comply with Duty to Co-operate

Reasons: I'm writing this email to officially object to the plan for housing off East Anglian way, Gorleston.

The area in question is a haven for wildlife (including Muntjac deer, various species of bird and other animals) which is much lacking in the local area.

The proposed entrance off East Anglian way would also be dangerous in my mind. The alternative emergency vehicle route off Colomb road is also impractical with Fire Engines already struggling to get down the road properly.

This area is used by many families foraging and enjoying the quiet tranquility. I feel more houses would spoil this and further stretch and already struggling hospital and local amenities such as schools and doctors.

I'm very much against the plans.

Suggested Modifications: It would be better somewhere else.

Request to be heard?: No

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 133 / Respondent: Tracy Brock

Date Received: 1/24/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB25

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Does not comply with Duty to Co-operate

Reasons:

I object to the building of houses on this piece of land which has become a wild biodiverse habitat full of trees , wildlife and birdsong. Areas like this are scarce in Gorleston and we should be looking at a progressive approach to conservation with the re wilding of areas of which this is one. Communities can reconnect with nature and the benefit on mental health of areas like this is well documented.

Building more houses is not sustainable or ethical here .

Suggested Modifications: I object to the building of houses on this piece of land which has become a wild biodiverse habitat full of trees , wildlife and birdsong. Areas like this are scarce in Gorleston and we should be looking at a progressive approach to conservation with the re wilding of areas of which this is one. Communities can reconnect with nature and the benefit on mental health of areas like this is well documented.

Building more houses is not sustainable or ethical here .

Request to be heard?: No

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 134 / Respondent: Maria Green

Date Received: 1/26/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB25

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Does not comply with Duty to Co-operate

Reasons: We are already over populated, schools are full, there is a lack of local employment. Deliberately having an increased volume of traffic next to a school is just dangerous.

The woodland you wish the build on is home to several fox families, muntjac, grey squirrel. These often venture to the outskirts of meadow park and give children a chance to witness our beautiful wildlife in the wild where they should be. The woodland contains wild flowers which the bees desperately need. Such a beautiful, if slightly wild, plot of land is the perfect habitat for wildlife who are continually forced out of their homes.

The abundance of beautiful, mature trees attract several bird species, offering a perfect home for many species who are in rapid decline.

Our green spaces are rapidly being taken from us for the purpose of building homes which we do not have the infrastructure for. It is virtually impossible to get a doctors appointment and literally impossible to see a dentist. Parking is problematic throughout gorleston with families having multiple vehicles. Schools and nurseries are full, we don't even have a local bank anymore!

Emergency vehicle access via either colomb road or Spencer avenue will undoubtedly be used by non emergency vehicles making a current cul de sac a through road, therefore decreasing the value of the properties.

Suggested Modifications: The woodland needs to be left as such in the interests of biodiversity.

Request to be heard?: Yes

Reason for Request to be heard:To ensure that the opinion of the public is heard and considered.

Attachments: N/A

Rep ID: 135 / Respondent: Michelle Rees

Date Received: 1/26/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB25

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Does not comply with Duty to Co-operate

Reasons: I would like to complain about houses being built on this site it would not be good for the wildlife and we don't need more houses when doctors schools hospitals dentists are over stretched also enough cars around here with the college near by already been a serious accident on this road

Suggested Modifications: Don't build in here

Request to be heard?: No

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 136 / Respondent: Mark Carter

Date Received: 1/27/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB25

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Does not comply with Duty to Co-operate

Reasons: The rear of my property is adjacent to the woodland which is to be destroyed for 70 homes. I have lived at my address since august 2017 and remember that plans were submitted in March 2018 for homes to be built on the land referenced on your proposal as URB25 between East Anglian Way and Gorleston recreation ground. The said proposal was eventually rejected. As I understand, it was considered far too dangerous to children of St Mary and St Peter School on East Anglian Way. There is already much traffic congestion when parents drop off and collect their children from school by car. This would be made worse by building 70 new homes with main access a small roadway near school, between 2 houses on East Anglian way. Many residents have concerns for very young children and the sheer density of traffic at said times.

There is also the environmental impact, as I understand, this small piece of woodland is the only land of its type for miles and I have observed wildlife such as muntjac deer, foxes, many species of bird, butterflies and bees. The land is also currently enjoyed by dog walkers and people simply enjoying a small part of nature in an otherwise urban environment.

Suggested Modifications: I would suggest that the danger to school children from ages 3+ from yet more traffic using the small road access of East Anglian Way would be made very severe by building a significant amount of houses next to the school.

I would also suggest that the woodland could be cleared, tidied or even developed for local residents including pupils of St Mary's and St Peter Roman Catholic school to enjoyed our diminishing wildlife.

Request to be heard?: No

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 137 / Respondent: Glenn Rees

Date Received: 1/27/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB25

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Does not comply with Duty to Co-operate

Reasons: As far as I can see there is no proper access road to build 70 houses on this site. And what about all the wild life what you going to do with them . As I live on spencer avenue there is no way that road is big enough and my bungalow was brought with the understanding it would remain a cul de sac .

Suggested Modifications: Until you find a proper assess to this site you should not be building 70 houses

Request to be heard?: No

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 138 / Respondent: Oliver Ross

Date Received: 1/28/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB25 4.241

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Does not comply with Duty to Co-operate

Reasons: Over the years there have been many attempts to build on this land all of which have been rejected for many reasons. All of these reasons still apply. For me personally the main reason is the extra traffic that and extra 70+ houses will create. When East Anglian Way was first developed the roads were made suitable for the amount of houses and vehicles that would reside on the road. That was over 30 years ago and a lot has changed. There are a lot more vehicles on the roads meaning more people park their cars on the road, this causes a lot of congestion even at normal times and weekends. You can't just drive in or out of the road without having to weave through parked cars. Add the primary school traffic and the road is at a practical standstill. If another 70+ houses are added I believe at least 100 cars would be using the road daily. I believe this is a very conservative estimate. That many extra cars would lead to absolute carnage at school drop off times. I am aware that's some land will be allocated to the school for a drop off/pick up area, however those cars will still have to get to this area. They will still need to drive down east Anglian way to access it. With residents cars parked on the road this will still result in gridlock due to the number of cars trying to get to the drop off/pick up area in a small amount of time.

Anyone who lives on the road will tell you that that traffic on the road is already excessive. Adding more cars to an already busy cul-de-sac would be a reckless decision.

I understand that new homes need to be built but the land backing on to East Anglian Way clearly isn't a viable or sensible option.

Suggested Modifications: There is no way that access can be safely made to this area for the amount of dwelling proposed, it is just too much for the current road system in this area

Request to be heard?: Yes

Reason for Request to be heard:Because history shows that the "little person" is often ignored by the people who hold the power. The option to push back is not one that I will walk away from. I will meet it head on and I will push hard to secure my home and surrounding area for myself

Attachments: N/A

Rep ID: 139 / Respondent: Graham Nourse Planning Consultants Ltd. on behalf of JDC Developments Ltd James

Date Received: 1/30/2025 9:51:00 AM

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy RUR1, Policy OSS3

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: This statement, prepared on behalf of JDC Developments Ltd, is provided in response to the current public consultation for the Great Yarmouth Local Plan Pre-Submission Document (Regulation 19). It is requested that this representation is considered by the Planning Inspector at the public examination into the Local Plan. This representation considers the need to allocate additional housing land within the village of Filby and the benefits of providing additional local housing. Under emerging policy RUR1 Filby is identified as a village which can accommodate additional housing development although no new allocation is being presented by the Council. In addition it is not clear whether the proposed Local Plan is fully compliant with the December 2024 version of the National Planning Policy Framework, particularly in relation to the calculation for housing land supply. As such the 'soundness' of the proposed Local Plan is questionable.

PROPOSED SITE - LAND OFF POUND LANE, FILBY

2.1 The site is located to the west of existing residential dwellings located on the west side of Pound Lane. The site, currently in agricultural use, is three sided adjoining residential development to the south west and eastern boundaries. The north boundary adjoins agricultural land. The site is relatively flat and laid to grass. A site access would be achieved between 16 and 17 Pound Lane. The site measures some 2.49 hectares and is referenced number S58 in the Councils Housing Economic Land Availability Assessment.

2.2 The Land Availability Assessment produced by the Council considered that the key reasons for not including the site as a formal allocation was that Pound Lane was unsuitable to serve additional development due to the relatively narrow width of the highway and the lack of a public footpath linking the site to Main Road (A1064). Additionally, the site was considered remote from public services as a result of the highway issues.

2.3 As noted emerging policy RUR1 identifies Filby as a village which can accommodate some additional housing. The only constraints to allocating the site related to the existing road access and the lack of a footpath giving access to village services. It perhaps should be noted that the village benefits from a primary school, village hall, sports pavilion, a post office/shop and a number of

local restaurants/public houses. The site at Pound Lane is within easy walking and cycling distance of all local services. Filby is therefore capable of supporting additional growth. It is likely that the site, taking into account of its location on the edge of the village, could comfortably accommodate between 40 and 60 dwellings.

2.4 The land can assist in the delivery of sustainable housing growth across the Borough over the next 20 years. The proposed land use is considered to be compliant with the National Planning Policy Framework December 2024, which contains a number of policies relevant to this proposal. Paragraph 8 of the NPPF identifies three overarching objectives to achieving sustainable development stating:

"Achieving sustainable development means that the planning system has three overarching objectives, which are interdependent and need to be pursued in mutually supportive ways (so that opportunities can be taken to secure net gains across each of the different objectives):

a) an economic objective - to help build a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and coordinating the provision of infrastructure;

b) a social objective - to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering well-designed, current and future needs and support communities' health, social and cultural well-being; and

c) an environmental objective - to protect and enhance our natural, built and historic environment; including making effective use of land, improving biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including moving to a low carbon economy".

2.5 The proposed development contributes to the local economy both in terms of providing additional employment during the course of building works and will also result in new occupants supporting existing local services. Development of the land would play a social role by providing additional housing, including affordable, to meet supply and is located in a sustainable location on the edge of Filby. Development of the site is considered sustainable.

2.6 Paragraphs 10 and 11 of the revised Framework refer to the presumption in favour of sustainable development. Paragraph 11 states:

"Plans and decisions should apply a presumption in favour of sustainable development.

For plan-making this means that:

a) all plans should promote a sustainable pattern of development that seeks to: meet the development needs of their area; align growth and infrastructure; improve the environment; mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects;

b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless:

i the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or

ii any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.

For decision-taking this means:

c) approving development proposals that accord with an up-to-date development plan without delay; or

d) where there are no relevant development plan policies, or the policies which are most important for determining the application are out-of-date8, granting permission unless:

i the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for refusing the development proposed; or

ii any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole, having particular regard to key policies for directing development to sustainable locations, making effective use of land, securing well-designed places and providing affordable homes, individually or in combination9".

2.7 Again the site is considered sustainable and suitable for residential development. It appears that no housing allocations are proposed for Filby in the Pre-Submission Plan which does appear an omission. This position does not allow for additional growth of the village which would support local demand for new and affordable housing. As noted the village does have a range of services but windfall development is unlikely to meet required housing needs. It is therefore considered essential that an allocation such as the Pound Lane site is provided.

2.8 Paragraph 36 of the NPPF refers to the 'soundness' of new Local Plans stating:

"Local plans and spatial development strategies are examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are 'sound' if they are:

Positively prepared - providing a strategy which, as a minimum, seeks to meet the area's objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving

sustainable development;

Justified - an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;

Effective - deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and

Consistent with national policy - enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant".

2.9 Again the omission of a housing allocation for Filby is not considered an appropriate strategy for the village and as noted may not meet the longer term housing needs of the village. It will be noted that the new draft Local Plan was issued prior to the new NPPF being published and it does not seem feasible that the Plan in its current form could be considered 'consistent with national policy' as clearly a number of key national policies have now changed, not least the revised criteria for housing land supply.

2.10 In terms of the site constraints the Council identified the existing highway and the resultant difficulties for new residents to access local services as being the key reasons as to why the site was not identified as a new housing allocation. In particular it suggested that part of the existing verge would be required to provide additional highway width and a public footpath. It should be noted that the existing verge on both sides of the highway is of significant width and it is clear that ample space exists for most of the highway leading to the main A1064 to be widened and a footpath/cycle way created. Space exists on the east side of the highway, as the A1064 is approached, to provide the required footpath. Technically it is possible to provide the required highway improvements and in the absence of any other critical issues to prevent development the site should be considered as an allocation in the new Local Plan.

2.0 CONCLUSION

2.1 In summary the proposed site is bounded by development on two sides and makes a logical extension to the village without extending the built form of the village into open countryside. As previously noted the existing highway is capable of being improved to provide an increased road width and footpath so removing the key objections raised by the Council. The proposed site would make a significant contribution towards future housing growth and affordable housing provision within Filby and the wider rural area, supporting both existing local services and those in adjoining villages.

2.2 In accordance with the revised NPPF sustainability should be at the heart of ensuring that new development is located in the appropriate place. The site is considered to be in a very sustainable location and in an appropriate location for residential development. The site should therefore be allocated as a site for future residential development and the draft Local Plan amended accordingly.

Suggested Modifications: Allocate land at Pound Lane, Filby - see response to question 5

Request to be heard?: Yes

Reason for Request to be heard:I believe it is important to provide a verbal explanation to the Inspector expanding as to why the proposed changes are necessary to make the Local Plan sound.

Attachments:

REP139 - Graham Nourse (Attachment 1) (PDF, 265 KB)(opens new window)

REP139 - Graham Nourse (Attachment 2) (PDF, 108 KB)(opens new window)

Rep ID: 140 / Respondent: Graham Nourse Planning Consultants Ltd. on behalf of Teresa

Date Received: 1/30/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy RUR1, Policy OSS3

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: INTRODUCTION

1.1 This statement, prepared on behalf of Ms Teresa Manguzi, is provided in response to the current public consultation for the Great Yarmouth Local Plan Pre-Submission Document (Regulation 19). It is requested that this representation is considered by the Planning Inspector at the public examination into the Local Plan. This representation considers an area of paddock land located immediately to the south west of an existing bungalow known as 'Threeways' on Mill Road, Burgh Castle and its suitability as an allocation for housing development in the new Local Plan (see location and site plan at Appendix A). The site measures 0.67 hectares and would be suitable for perhaps a small group of 5 to 6 dwellings reflecting the existing density of development in the locality.

1.2 The proposed site is considered to be in a sustainable location and reflects planning policy contained at national level in the December 2024 National Planning Policy Framework. Although currently outside the Development Limits boundary for Burgh Castle as identified in the current Local Plan, the site is located just a short distance from the existing development limits boundary. Taking into account the sizeable number of existing residential properties which exist on Mill Road, particularly on the west side of the road, it is considered that the Development Limits boundary should be extended to include Mill Road and the proposed development site within a revised Development Limits boundary for the village. It is suggested that the Development Limits boundary be extended along the west side of Mill Road upto the Parkdean holiday park. It perhaps should also be noted that the Council have approved a number of infill dwellings on Mill Road in recent years including two bungalows at a property known as 'Strawlands', located some distance to the north of 'Threeways'. This development was approved under application reference 06/19/0036/F.

1.3 The purpose of this submission is to demonstrate that the site can assist in the delivery of sustainable housing growth across the Borough during the next 20 years. As well as being in a sustainable location the site is also capable of being delivered quickly for development. Extension of the Development Limits boundary would also assist in providing a small amount of additional infill development on Mill Road.

1.4 Under emerging policy RUR1 Burgh Castle is identified as a smaller village which can accommodate smaller scale housing growth. In addition it is not clear whether the draft Local Plan is fully compliant with the December 2024 version of the National Planning Policy Framework, particularly in relation to the calculation for housing land supply as well as the choice of sites for allocation. As such the 'soundness' of the proposed Local Plan is questionable.

2.0 PROPOSED SITE - LAND ADJOINING 'THREEWAYS', MILL ROAD, BURGH CASTLE.

2.1 As noted the proposed site can accommodate upto 6 dwellings accessed directly from Mill Road. Development would be considered 'small-scale' reflecting policy RUR1. The site is currently in use as paddock land but adjoins residential development and a large holiday complex to the north-east and residential development to the south-west. An established vehicular access into the site already exists from Mill Road and the access can be upgraded to serve a small group of dwellings. The site has no contamination and has established infrastructure connections.

2.2 It is also suggested that the existing Development Limits boundary is extended to include the site, on the west side of Mill Road. The proposed Development Limits policy OSS3 states:

"Development Limits are defined on the Policies Map. Development will be supported in principle within the Development Limits subject to compliance with other relevant policies in the development plan. Development will not be permitted on land outside of Development Limits except where: a) It is on a site allocated for development within this Local Plan or in a Neighbourhood Plan for the uses specified in the allocation policy; b) it comprises agricultural or forestry development; c) it comprises the provision of utilities and highway infrastructure; or d) specific policies in the Local Plan indicate otherwise".

2.3 The suggested change to the boundary line would potentially enable additional windfall development to take place along Mill Road contributing towards housing land supply and supporting existing local services found within the village and in nearby Belton all of which are within walking or cycling distance.

2.4 The draft Local Plan does allocate one site for housing within the village - BUR1 which is proposed to accommodate upto 20 dwellings. The site is accessed via Louis Dahl Road and appears as a distinct extension into open countryside. By extending the Development Limits boundary as suggested on Mill Road it would potentially provide a similar number of infill plots in a sustainable location. The need to provide a somewhat random 'backland' extension into countryside such as BUR1 could possibly be avoided.

2.5 The proposed Development Limits boundary, suggested in this statement, would assist in the delivery of sustainable housing growth across the Borough over the next 20 years. The proposed boundary extension and small allocation is considered to be compliant with the National Planning Policy Framework December 2024, which contains a number of policies relevant to this proposal. Paragraph 8 of the NPPF identifies three overarching objectives to achieving sustainable development stating:

2.6 The proposed boundary extension and inclusion of a small housing allocation contributes to the local economy both in terms of providing additional employment during the course of building works and will also result in new residents supporting existing local services. Development of the land would play a social role by providing additional housing to meet supply and is located in a sustainable location close to services within the village and nearby Belton.

2.7 Paragraphs 10 and 11 of the revised Framework refer to the presumption in favour of sustainable development. Paragraph 11 states:

"Plans and decisions should apply a presumption in favour of sustainable development.

For plan-making this means that:

b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless:

ii any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.

For decision-taking this means:

c) approving development proposals that accord with an up-to-date development plan without delay; or

d) where there are no relevant development plan policies, or the policies which are most important for determining the application are out-of-date8, granting permission unless:

i the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for refusing the development proposed; or

2.8 Again the extension of the development limits as proposed is considered sustainable and more preferable perhaps to allocation BUR1. In any event provision of additional sustainable sites housing would enable the Council to exceed their minimum housing target provision.

2.9 Paragraph 36 of the NPPF refers to the 'soundness' of new Local Plans stating:

sustainable development;

Justified - an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;

Consistent with national policy - enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant".

2.10 It is considered a missed opportunity to not consider extending the existing Development Limits boundary along Mill Road as suggested. As noted the west side of Mill Road, in particular, is relatively built up with a number of existing dwellings, mainly set in linear form, along the western frontage upto the Parkdean holiday park. It will also be noted that the new draft Local Plan

was issued prior to the revised NPPF being published and it does not seem feasible that the draft Plan in its current form could be considered 'consistent with national policy' as clearly a number of key national policies have now changed, not least the revised criteria for housing land supply and the possible need to consider additional provision.

3.0 CONCLUSION

3.1 In summary by extending the existing Development Limits boundary and allocating the site as a small housing allocation it will provide a modest contribution towards future housing growth within Burgh Castle reflecting policy RUR1. The site is available for development and could provide an immediate contribution towards housing supply.

3.2 In accordance with the NPPF sustainability should be at the heart of ensuring that new development is located in the appropriate place. The site is considered to be in a very sustainable location close to existing village services. Extension of the development limits boundary and a small allocation for housing would not cause harm to the character of the locality or impact on open

countryside.

3.3 In conclusion the site is considered an appropriate location for an allocation as residential development within the Local Plan. It is therefore requested that the Development Limits boundary be extended along Mill Road as suggested and a small allocation for housing made.

Suggested Modifications: See Question 5 response - by extending the existing Development Limits boundary and allocating the site as a small housing allocation it will provide a modest contribution towards future housing growth within Burgh Castle reflecting policy RUR1. The site is available for development and could provide an immediate contribution towards housing supply.

Request to be heard?:

Reason for Request to be heard:

Attachments:

REP140 - Graham Nourse (Attachment 1) (PDF, 61 KB)(opens new window)

REP140 - Graham Nourse (Attachment 2) (PDF, 113 KB)(opens new window)

Rep ID: 141 / Respondent: Civic Society of Great Yarmouth Hugh - Hugh Sturzaker

Date Received: 1/30/2025

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy OSS1

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: The Borough of Great Yarmouth desperately needs more good housing for its expanding population. Many of the Victorian houses in the centre of Great Yarmouth are in poor condition but have great potential to be attractive. However money is needed to bring them up to modern day standards.

Many of the new houses recently built have very small rooms and I have heard many criticisms about the standard of build and there needs to be greater overseeing of the plans and the standards of building.

We need to attract people with money into the town so high class executive houses in certain areas e.g. overlooking the river in North Quay need to be built.

URB21. The main problem here is the extra traffic it will bring into Links Road. This could be helped by widening the road.

URB4 North Quay. This has great potential and I would hope that the area along the river will have some executive homes to attract people with money to come and live and spend their money in the town.

CAS1 The main complaint from people living in Caister is that in spite of expansion over the years there has been no increase in amenities e.g. dentists and GP Surgeries. I gather that it is the responsibility of the NHS to provide these facilities although the Borough provides the land. Can more pressure be put on the NHS?

Great Yarmouth has several disjointed areas: town centre, seafront, cultural centre, train station etc. The provision of robotic vehicles powered by electricity or hydrogen would help link these places together and would be a tourist attraction.

Suggested Modifications:

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 142 / Respondent: Pegasus Group on behalf of Great Yarmouth Port Company

Date Received: 1/24/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB1

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: -

Suggested Modifications: Policy text for Policy URB1 remains as previously discussed, as does the specific text relating to the South Denes area (Spatial Objective 10).

GYPC sought clarity on the requirement for Supplementary Plans and whether they should apply to the opportunity areas as a whole or certain parts of the opportunity area, what the process would be in preparing such plans, and what status these plans would have. They also request 'Figure 3 - Urban Regeneration Opportunity Areas Map 1' encapsulates the full extent of the port estate.

It does not appear that there have been additional clarifications added to the Pre-Submission version of the Local Plan. GYPC remain of the opinion it would be beneficial for the explanatory notes associated with the Policy to detail the proposed use and scale of a Supplementary Plan, how it would be prepared and its status within policy.

The Urban Regeneration Opportunity Areas Map (now Figure 7), also hasn't been updated to indicate GYPC ownerships under one area; GYPC own land to the west of the River Yare which has fallen into a different opportunity area on this map, splitting the Port Estate.

Request to be heard?: No

Reason for Request to be heard:-

Attachments: REP142-147 - Great Yarmouth Port Company (PDF, 783 KB)(opens new window)

Rep ID: 143 / Respondent: Pegasus Group on behalf of Great Yarmouth Port Company

Date Received: 1/24/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB16

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: -

Suggested Modifications: Policy URB14 (now URB16) - Great Yarmouth South Denes Port and Harbour Area

Policy text for URB16 is broadly similar to the previous iteration, with minor text change under part 'f' and 'g'.

GYPC requested more clarity as to what development could be considered ancillary to port use; this has been updated in the policy under parts 'f' and 'g', and its supporting text to describe developments will be permitted only where they cannot be accommodated elsewhere in the borough, and where they don't undermine port related uses. However, the policy nor its supporting text provide specifics as to what an ancillary use could consist of.

The Regulation 18 version also referred to giving businesses assistance to relocate elsewhere where this frees up land to strengthen port related activities; it was requested that clarification should be made as to who would provide this assistance and how, but this matter remains unresolved.

Request to be heard?: No

Reason for Request to be heard:-

Attachments: REP142-147 - Great Yarmouth Port Company (PDF, 783 KB)(opens new window)

Rep ID: 144 / Respondent: Pegasus Group on behalf of Great Yarmouth Port Company

Date Received: 1/24/2025

Section of the Plan: 9

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy EMP2

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Policy EMP2 - Protected Employment Sites

Policy text for EMP2 remains as per the previous iteration of the plan. GYPC have no further comment on this policy and reiterate our previous representations, that it is a useful tool to ensure that sufficient floorspace is retained within the area to support economic growth.

Suggested Modifications: -

Request to be heard?: No

Reason for Request to be heard:-

Attachments: REP142-147 - Great Yarmouth Port Company (PDF, 783 KB)(opens new window)

Date Received: 1/30/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy BEL1, RUR1, OSS3

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons:

1.0 INTRODUCTION

1.1 This statement, prepared on behalf of Mr Jamie Woodrow, is provided in response to the current public consultation for the Great Yarmouth Local Plan Pre-Submission Document (Regulation 19). It is requested that this representation is considered by the Planning Inspector at the public examination into the Local Plan. This representation considers the need to retain the existing settlement boundary line for Belton to include land at Whitethorn Lodge, New Road and the land immediately to the west of Whitethorn Lodge located between Whitethorn Lodge and Stepshort. This area of land is considered as being more sustainable than the proposed allocation on the opposite side of New Road (BN1) and represents natural infill not extending the area of built development into open countryside. Under emerging policy RUR1 Belton is identified as a larger village which can accommodate additional housing allocations. In addition it is not clear whether the proposed Local Plan is fully compliant with the December 2024 version of the National Planning Policy Framework, particularly in relation to the calculation for housing land supply as well as the choice of sites for allocation. As such the 'soundness' of the proposed Local Plan is questionable.

2.0 PROPOSED SITE - LAND ADJOINING NEW ROAD/WHITETHORN LODGE.

2.1 The adopted Local Plan for Belton includes a housing allocation BEL1 which is proposed to be retained within the new draft Local Plan as proposed allocation BEL1. However it is noted, with concern, that the existing adopted Development Limits boundary for Belton is proposed to change, excluding both Whitethorn Lodge on the opposite side of New Road, along with land immediately to the west of Whitethorn Lodge (see Appendix A and B Local Plan maps). The proposed Development Limits policy OSS3 states:

allocated for development within this Local Plan or in a Neighbourhood Plan for the uses specified in the allocation policy; b) it comprises agricultural or forestry development; c) it comprises the provision of utilities and highway infrastructure; or d) specific policies in the Local Plan indicate otherwise".

2.2 The proposed change to the boundary line has a significant impact on Whitethorn Lodge and the land to the west which is also excluded from the development limits. This is somewhat surprising as the land to the west has previously been granted Planning Permission for 64 dwellings under application ref 06/05/2016.

2.3 The current Development Limits boundary closely follows the existing Parish boundary line for Belton and it was logical to include that original defined boundary as the limit for further development within the village. It is not clear why this change has been made.

2.4 Emerging policy RUR1 identifies Belton as a large village with a range of services and capable of accommodating additional housing growth. Site allocation BEL1, located on the opposite side of New Road, is proposed to accommodate upto 100 dwellings. The supporting text in the draft Local Plan for BEL1 notes that the land to the east of BEL1 forms part of the strategic gap between Belton and Bradwell. Again it does not seem appropriate to allocate a site which clearly extends the village boundary further into open countryside and also removes part of the strategic gap. It seems far more logical to extend the Development Limits boundary on the opposite side of New Road, as previously discussed, which would have far less impact.

2.5 The proposed Development Limits boundary, suggested in this statement, would assist in the delivery of sustainable housing growth across the Borough over the next 20 years. The proposed boundary extension is considered to be compliant with the National Planning Policy Framework December 2024, which contains a number of policies relevant to this proposal. Paragraph 8 of the NPPF identifies three overarching objectives to achieving sustainable development stating:

b) a social objective - to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering well-designed, beautiful and safe places, with accessible services and open spaces that reflect current and future needs and support communities' health, social and cultural well-being; and

2.6 The proposed boundary extension and inclusion of a housing allocation contributes to the local economy both in terms of providing additional employment during the course of building works and will also result in new residents supporting existing local services. Development of the land would play a social role by providing additional housing, including affordable, to meet supply and is located in a sustainable location on the edge of Belton.

2.7 Paragraphs 10 and 11 of the revised Framework refer to the presumption in favour of sustainable development. Paragraph 11 states:

"Plans and decisions should apply a presumption in favour of sustainable development.

For plan-making this means that:

b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless:

ii any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.

For decision-taking this means:

c) approving development proposals that accord with an up-to-date development plan without delay; or

d) where there are no relevant development plan policies, or the policies which are most important for determining the application are out-of-date8, granting permission unless:

i the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for refusing the development proposed; or

2.8 Again the extension of the development limits as proposed is considered sustainable and more preferable to allocation BEL1. Even if BEL1 is retained

in the adopted version of the Local Plan, Belton is quite capable of accommodating additional growth and allocations taking into account its range of services and proximity to Gorleston and Great Yarmouth.

2.9 Paragraph 36 of the NPPF refers to the 'soundness' of new Local Plans stating:

Justified - an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;

Consistent with national policy - enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant".

2.10 The reduction in the development limits boundary effectively reducing the available land for new housing is not considered an appropriate strategy for the village, particularly with allocation BEL1 appearing as a distinct extension into open countryside. It will be noted that the new draft Local Plan was issued prior to the revised NPPF being published and it does not seem feasible that the draft Plan in its current form could be considered 'consistent with national

policy' as clearly a number of key national policies have now changed, not least the revised criteria for housing land supply.

2.0 CONCLUSION

2.1 In summary the land in question is currently located within the Development Limits boundary of the adopted Local Plan and would make a significant contribution towards future housing growth within Belton and the wider rural area, supporting both existing local services and those in adjoining villages.

2.2 In accordance with the NPPF and Local Plan policy sustainability should be at the heart of ensuring that new development is located in the appropriate place. The site is considered to be in a very sustainable location close to existing village services. Extension of the development limits boundary and allocation for housing would not cause harm to the character of the locality or impact on open countryside. It would have far less visual impact than allocation BEL1.

2.3 In conclusion the site is considered an appropriate location for residential development and the proposed Local Plan Development Limits boundary should be altered to reflect the current adopted Local Plan boundary and also include the additional area of land immediately north of Whitethorn Lodge as shown on Appendix C. It is therefore requested to amend the Development Limits boundary accordingly and to allocate the land for future residential development.

Suggested Modifications: see question 5 response

Request to be heard?: Yes

Reason for Request to be heard:I believe it is important to verbally expand on the reasons submitted for the proposed changes to the Local Plan before the Planning Inspector.

Attachments:

REP148 - Graham Nourse (Attachment 1) (PDF, 110 KB)(opens new window)

REP148 - Graham Nourse (Attachment 2) (PDF, 171 KB)(opens new window)

REP148 - Graham Nourse (Attachment 3) (PDF, 201 KB)(opens new window)

REP148 - Graham Nourse (Attachment 4) (PDF, 111 KB)(opens new window)

Rep ID: 149 / Respondent: Rosie Moyce

Date Received: 1/30/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB25

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: To build on valuable woodland goes against environmental policy to preserve local natural habitat . The small remaining woodland at meadow park provides habitat for wild animals . It is a criminal offence to intentionally harm wild animals . Hence how can you destroy their only surviving resources .

Additionally the local community enjoy this area . Green space is vital for our health and wellbeing .

Build houses on brown land site instead.

Suggested Modifications: Build houses on land that is brown field site only .

Request to be heard?: No

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 150 / Respondent: Savills (UK) Ltd on behalf of Asda Stores Ltd

Date Received: 1/29/2025

Section of the Plan: 12

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HEC8 12.47

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: We note that Policy HEC8 (criteria d-h) which relates to drive thru facilities, has been moved from Policy RTC2 (Edge of Centre and Out of Centre Retail and Town Centre Use Developments). Criterion d) sets out that such uses must be located along the A47 or otherwise benefit from good access to the A47.

Whilst Policy RTC2 dealt with drive thru facilities outside of a defined centre, the relocation of this text to Policy HEC8 now applies this criteria to drive thru uses located both within and outside of defined centres.

At the outset and as a main town centre use (and recognised as such at Paragraph 12.47), the starting point for any such development is the sequential approach, which in the first instance seeks to locate such uses within centres. The current wording, which seems to be an unintended consequence of the relocation from Policy RTC2, is that HEC8(d) does not accord with the sequential approach, as it gives preference to locating such uses outside of a defined centre.

Paragraph 12.47 suggests that criteria f) sets out that designated centres must be considered first. However this only states: "...f) be of a design that complements existing commercial units within the vicinity, or in the absence of other units, responds to the sensitivity of the countryside". This therefore clearly relates to design matters and has no relationship to seeking the location of such facilities within town centres first, in accordance with the sequential approach.

In order to accord with the sequential approach enshrined in national policy, we recommend that criteria d) be amended to state:

"d) such uses should follow the sequential approach under Policies RTC1 and RTC2 and only where there are no available or suitable in or edge-of-centre sites, should then be located along the A47 trunk road or otherwise benefit from good access to the A47, for the principal aim to serve travelling vehicles along that corridor."

Paragraph 12.47 also requires amending in order to correct the error in relation to criteria f) and then for consistency with the amended wording as suggested above.

Suggested Modifications: In order to accord with the sequential approach enshrined in national policy, we recommend that criteria d) be amended to state:

Paragraph 12.47 also requires amending in order to correct the error in relation to criteria f) and then for consistency with the amended wording as suggested above.

Request to be heard?: Yes

Reason for Request to be heard:In order that the matters raised in our client's representations can be fully explored.

Attachments: REP150-152 - ASDA Stores Ltd CO Savills (PDF, 492 KB)(opens new window)

Rep ID: 151 / Respondent: Savills (UK) Ltd on behalf of Asda Stores Ltd

Date Received: 1/29/2025

Section of the Plan: 10

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy RTC1 10.6

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: As set out above in relation to Policy URB18, our client supports the identification of the new District Centre at Beacon Park, which is identified in Policy RTC1 along with the existing District Centre at Caister-on-Sea.

We do however maintain our previous concerns in relation to the wording and interpretation of criteria (c)(ii) of the policy. This sets out that proposals within the District Centres should "consider the cumulative impacts of development or clustering of specific uses that have the potential to harm the vitality of the centre".

As set out in relation to the Regulation 18 Consultation, this is ambiguous and could be construed as meaning that any in-centre development requires a cumulative retail impact assessment. Our previous representations set this out in detail, but in particular:

- It conflicts with paragraph 16(d) of the NPPF, which sets out that Plans should contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals.

- There is also the potential for conflict between this criteria and the specific policy allocation for Beacon Park District Centre. For example, Policy URB18 (previously URB16) permits food and drink uses, but under RTC1 it could be construed as discouraging more than one such food and drink use, which we do not believe is the intention of Policy RTC1.

- Given that there is a specific policy for Beacon Park District Centre, any specific requirements for it should be explicitly incorporated into Policy URB18, which sets out the type of uses within the Centre that are appropriate. This would then accord with NPPF paragraph 16(d) as above, and also paragraph 16(f) which requires Plans to serve a clear purpose and avoid unnecessary duplication of policies that apply to a particular area.

We note that additional Paragraph 10.6 has been added, which the Council's Consultation Statement (November 2024) sets out addresses this matter. In particular, the Consultation Statement states that it is not the intention to require a Retail Impact Assessment for in-centre development as this would be contrary to national policy. We fully agree that is the Council's intention, but the ambiguity in the wording of the Policy could lead to a different view being formed. Therefore, for the avoidance of any doubt, paragraph 10.6 should be revised in order to be explicit in relation to this matter.

Suggested Modifications: It was suggested that supporting paragraph 10.6 to Policy RTC1 should clarify that a retail impact assessment is not required for in-centre retail development.

Request to be heard?: Yes

Reason for Request to be heard:In order that the matters raised in our client's representations can be fully explored.

Attachments: REP150-152 - ASDA Stores Ltd CO Savills (PDF, 492 KB)(opens new window)

Rep ID: 152 / Respondent: Savills (UK) Ltd on behalf of Asda Stores Ltd

Date Received: 1/29/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB18

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Our client fully supports the principle of the new District Centre at Beacon Park and the changes made to the 1st paragraph following the Regulation 18 Consultation. It also supports the proposed permitted uses under criteria a) to c).

The provision of this District Centre and its proposed uses will support existing and future residents and businesses in this growth area.

Suggested Modifications: -

Request to be heard?: No

Reason for Request to be heard:-

Attachments: REP150-152 - ASDA Stores Ltd CO Savills (PDF, 492 KB)(opens new window)

Rep ID: 153 / Respondent: Water Management Alliance

Date Received: 12/17/2024

Section of the Plan: 14

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CLC2

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: -

Suggested Modifications: I note that the draft plan references sustainable development in terms of flood risk, noting that development cannot necessarily be steered away from areas at risk of flooding due to the nature of Great Yarmouth's coastal location. Whilst the geography of the district poses a challenge to sustainable development in terms of flood risk, I recommend that the Local Plan includes reference to the relevant regulators for drainage and flood risk including the Internal Drainage Boards. These agencies are in place to support the provision of sustainable development and reducing flood risk. As outlined above, works to watercourses (such as surface water discharges and/or any alterations of said watercourses) will require consent from the relevant regulatory body, therefore it would be beneficial for the Boards to be included in the plan where consents may be required.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP154-181 - Marine Management Organisation (PDF, 254 KB)(opens new window)

Rep ID: 154 / Respondent: Marine Management Organisation Charlotte Lewis

Date Received: 1/24/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT6

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: • Previous recommendation: Policy NAT6 - Norfolk Coast National Landscape and the Broads. Development proposals which are considered to have a potential adverse impact on landscape and seascape (if applicable) character and all major development proposals within the Norfolk Coast National Landscape should be informed by a Landscape and Visual Impact Assessment that is proportionate to the scale of the development and in accordance with best practice.

o Further comments: Seascape has been included in the Local Plan. Many thanks for revising.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP154-181 - Marine Management Organisation (PDF, 254 KB)(opens new window)

Rep ID: 155 / Respondent: Marine Management Organisation Charlotte Lewis

Date Received: 1/24/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: • Previous recommendation: Sensitive designated habitats: It is identified within the local plan that disturbance can negatively impact watercourses, which also results in impacts on the marine environment (aligned with East Marine Plans policy ECO1, TR1, BIO1 and BIO2).

o Further comments: Great Yarmouth note that Policies NAT1-NAT5, Policy HCE3 and Policy DHE1 provide a comprehensive approach to the protection and enhancement of habitats and biodiversity in the borough.

Suggested Modifications: MMO recommend more consideration around limiting disturbance and negative impacts to watercourses, as this results in impacts on the marine environment.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP154-181 - Marine Management Organisation (PDF, 254 KB)(opens new window)

Rep ID: 156 / Respondent: Marine Management Organisation Charlotte Lewis

Date Received: 1/24/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT2

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Suggested Modifications: MMO recommend more consideration around limiting disturbance and negative impacts to watercourses, as this results in impacts on the marine environment.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP154-181 - Marine Management Organisation (PDF, 254 KB)(opens new window)

Rep ID: 157 / Respondent: Marine Management Organisation Charlotte Lewis

Date Received: 1/24/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT3

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Suggested Modifications: MMO recommend more consideration around limiting disturbance and negative impacts to watercourses, as this results in impacts on the marine environment.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP154-181 - Marine Management Organisation (PDF, 254 KB)(opens new window)

Rep ID: 158 / Respondent: Marine Management Organisation Charlotte Lewis

Date Received: 1/24/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT4

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Suggested Modifications: MMO recommend more consideration around limiting disturbance and negative impacts to watercourses, as this results in impacts on the marine environment.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP154-181 - Marine Management Organisation (PDF, 254 KB)(opens new window)

Rep ID: 159 / Respondent: Marine Management Organisation Charlotte Lewis

Date Received: 1/24/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT5

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Suggested Modifications: MMO recommend more consideration around limiting disturbance and negative impacts to watercourses, as this results in impacts on the marine environment.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP154-181 - Marine Management Organisation (PDF, 254 KB)(opens new window)

Rep ID: 160 / Respondent: Marine Management Organisation Charlotte Lewis

Date Received: 1/24/2025

Section of the Plan: 12

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HEC3

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Suggested Modifications: MMO recommend more consideration around limiting disturbance and negative impacts to watercourses, as this results in impacts on the marine environment.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP154-181 - Marine Management Organisation (PDF, 254 KB)(opens new window)

Rep ID: 161 / Respondent: Marine Management Organisation Charlotte Lewis

Date Received: 1/24/2025

Section of the Plan: 15

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy DHE1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Suggested Modifications: MMO recommend more consideration around limiting disturbance and negative impacts to watercourses, as this results in impacts on the marine environment.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP154-181 - Marine Management Organisation (PDF, 254 KB)(opens new window)

Rep ID: 162 / Respondent: Marine Management Organisation Charlotte Lewis

Date Received: 1/24/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT7

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: • Previous recommendations: Poor overall level of health and wellbeing: The East Marine Plans recognise the benefits of access to the marine environment and supports projects and initiatives to improve wellbeing and health (East Marine Plan policy SOC1).

o Further comments: Great Yarmouth note that Policy NAT7 and Policy NAT6 aim to protect specific areas

Suggested Modifications: We recommend that emphasis and recognition is given to the benefits of access to the marine environment, and that projects and initiatives to improve wellbeing and health are supported.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP154-181 - Marine Management Organisation (PDF, 254 KB)(opens new window)

Rep ID: 163 / Respondent: Marine Management Organisation Charlotte Lewis

Date Received: 1/24/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT6

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

o Further comments: Great Yarmouth note that Policy NAT7 and Policy NAT6 aim to protect specific areas

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP154-181 - Marine Management Organisation (PDF, 254 KB)(opens new window)

Rep ID: 164 / Respondent: Marine Management Organisation Charlotte Lewis

Date Received: 1/24/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB10

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: • Previous recommendations: SOC2 marine plan policy presents some interest with regard to marine heritage assets and may be worth consideration in the context of heritage led regeneration.

Suggested Modifications: We recommend for Great Yarmouth to make regard to the SOC2 marine plan policy in relation to heritage policies, Policy URB10, Policy CAS1, Policy URB4

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP154-181 - Marine Management Organisation (PDF, 254 KB)(opens new window)

Rep ID: 165 / Respondent: Marine Management Organisation Charlotte Lewis

Date Received: 1/24/2025

Section of the Plan: 5

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CAS1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Suggested Modifications: We recommend for Great Yarmouth to make regard to the SOC2 marine plan policy in relation to heritage policies, Policy URB10, Policy CAS1, Policy URB5

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP154-181 - Marine Management Organisation (PDF, 254 KB)(opens new window)

Date Received: 1/24/2025

Section of the Plan: 14

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:14.39

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: The Water Framework Directive (WFD) sets out the need to protect and improve the water environment, applying to all surface water bodies including rivers, streams, lakes, groundwater bodies and coastal waters out to one mile from low water. The Marine Strategy sets out a comprehensive framework for assessing, monitoring and taking action across our seas to achieve the UK's shared vision for clean, healthy, safe, productive and biologically diverse seas.

o Further comments: Many thanks for inclusion of the Marine Strategy in supporting text 14.39.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP154-181 - Marine Management Organisation (PDF, 254 KB)(opens new window)

Rep ID: 172 / Respondent: Marine Management Organisation Charlotte Lewis

Date Received: 1/24/2025

Section of the Plan: 15

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy DHE1

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Policy DHE1 - Design. All development, including extensions and alterations to existing buildings must achieve high quality sustainable design that contributes positively to local character, landscape, seascape (if applicable) and townscape, and supports diversity, equality and access for all in accordance with the criterion below and the Design Code (Appendix 1).

o Further comments: Many thanks for inclusion of seascape in Policy DHE1.

Suggested Modifications:

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP154-181 - Marine Management Organisation (PDF, 254 KB)(opens new window)3

Rep ID: 173 / Respondent: Marine Management Organisation Charlotte Lewis

Date Received: 1/24/2025

Section of the Plan: 15

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy DHE1

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: : B) i. Be based upon and reflect a sound understanding of the local context, including the surrounding built environment, urban grain, topography, landscape, seascape (if applicable), drainage and locally important key views in accordance with Criterion CI1 of the Design Code (Appendix 1) and the relevant character areas and development type sections of the Design Code (Appendix 1).

o Further comments: Many thanks for inclusion of seascape in Policy DHE1.

Suggested Modifications:

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP154-181 - Marine Management Organisation (PDF, 254 KB)(opens new window)

Rep ID: 174 / Respondent: Marine Management Organisation Charlotte Lewis

Date Received: 1/24/2025

Section of the Plan: 14

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CLC4

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: • Previous recommendation: Policy CLC4: Renewable and Low-Carbon Energy Development. g) Water Quality and water resources (including groundwater, coastal waters...).

Suggested Modifications: It was recommend to include coastal waters in the Water Quality and water resources text.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP154-181 - Marine Management Organisation (PDF, 254 KB)(opens new window)

Rep ID: 175 / Respondent: Marine Management Organisation Charlotte Lewis

Date Received: 1/24/2025

Section of the Plan: 15

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy DHE1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: • Previous recommendation: Policy DHE1 - Design. Provide a sufficient quantity, type and quality of public open and green and blue infrastructure and where relevant access to watercourses in accordance with Policy HEC2 and criterion PS2 and PS3 of the Design Code (Appendix 1) and the relevant character areas and development type sections of the Design Code (Appendix 1).

Suggested Modifications: Recommend the inclusion of blue infrastructure.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP154-181 - Marine Management Organisation (PDF, 254 KB)(opens new window)

Rep ID: 176 / Respondent: Marine Management Organisation Charlotte Lewis

Date Received: 1/24/2025

Section of the Plan: 14

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CLC4

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: • Previous recommendation: Policy CLC4: Renewable and Low-Carbon Energy Development. If this policy is not in relation to offshore renewables then it should be clarified. If it is in relation to offshore renewables then the following statement below should be considered. No specific reference is given to the development of offshore renewables and the associated infrastructure required. It should be noted that Great Yarmouth has and will continue to play a key role in facilitating and servicing offshore wind farms (Scroby Sands, East Anglia Three, Norfolk Vanguard East and West, Norfolk Boreas). If this policy is in relation to offshore renewable energy then supporting text should clarify the role of the MMO and the necessity to collaborate with the East Marine Plans as well as the Great Yarmouth Local Plan, as identified in Policy URB14 section 4.138.

Suggested Modifications: There is some clarification in the Local Plan around the type of renewable and low-carbon energy listed under this policy, being terrestrial based. In regard to the comments in the Consultation Statement, we still recommend further revisions around offshore wind proposals in relation to the East Marine Plan policy EC3: No specific reference is given to the development of offshore renewables and the associated infrastructure required. It should be noted that Great Yarmouth has and will continue to play a key role in facilitating and servicing offshore wind farms (Scroby Sands, East Anglia Three, Norfolk Vanguard East and West, Norfolk Boreas). If this policy is in relation to offshore renewable energy then supporting text should clarify the role of the MMO and the necessity to collaborate with the East Marine Plans as well as the Great Yarmouth Local Plan, as identified in Policy URB14 section 4.138.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP154-181 - Marine Management Organisation (PDF, 254 KB)(opens new window)

Rep ID: 177 / Respondent: Marine Management Organisation Charlotte Lewis

Date Received: 1/24/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB16

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: The map associated with this policy relates only to the terrestrial portion of the borough, excluding the marine environment within the outer harbour, despite the boundary of the borough extending beyond. We would be interested to understand the reason for excluding the water within the outer harbour. The map is mis-leading and suggests anything outside of this policy area is either not supported for the development of renewables or is no longer in the interests of the council. A reason for this may be due to the statutory harbour area boundary, and if this is the case then it needs to be clarified within the supporting text.

Suggested Modifications: Fig. 8 of the Local Plan includes Great Yarmouth seafront. Cannot locate the Urb14 map that is being referenced in the previous recommendation

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP154-181 - Marine Management Organisation (PDF, 254 KB)(opens new window)

Rep ID: 178 / Respondent: Marine Management Organisation Charlotte Lewis

Date Received: 1/24/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB15

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: • Previous recommendation: Policy URB13 - Gorleston Seafront. Addition of text in supporting text: There may be a requirement for infrastructure that may need to consider the requirement for a marine licence for works which take place below the mean high-water mark. This should be done in consultation with the Marine Management Organisation and with regard to Marine Policy Statement (September 2011) and the East Inshore and East Offshore Marine Plans (April 2014) . Works within 16m of the existing flood defences would also require a Flood Risk Activity Permit from the Environment Agency. It will also be necessary to consider and agree the site approach to flood risk management with the Lead Local Flood Authority and Borough Council.

Suggested Modifications: It was recommended that the supporting text is updated as: "There may be a requirement for infrastructure that may need to consider the requirement for a marine licence for works which take place below the mean high-water mark. This should be done in consultation with the Marine Management Organisation and with regard to the Marine Policy Statement (September 2011) and the East Inshore and East Offshore Marine Plans (April 2014). Works within 16m of the existing flood defences would also require a Flood Risk Activity Permit from the Environment Agency. It will also be necessary to consider and agree the site approach to flood risk management with the Lead Local Flood Authority and Borough Council".

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP154-181 - Marine Management Organisation (PDF, 254 KB)(opens new window)

Rep ID: 179 / Respondent: Marine Management Organisation Charlotte Lewis

Date Received: 1/24/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB16

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: 4.138 additional text required: Future developments may require the need to consider the requirement for a marine licence for works which take place below the mean high-water mark. This should be done in consultation with the Marine Management Organisation and with regard to Marine Policy Statement (September 2011) and the East Inshore and East Offshore Marine Plans (April 2014) . Works within 16m of the existing flood defences would also require a Flood Risk Activity Permit from the Environment Agency. It will also be necessary to consider and agree the site approach to flood risk management with the Lead Local Flood Authority and Borough Council.

Suggested Modifications: Recommend the above text is included in the Local Plan.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP154-181 - Marine Management Organisation (PDF, 254 KB)(opens new window)

Rep ID: 180 / Respondent: Marine Management Organisation Charlotte Lewis

Date Received: 1/24/2025

Section of the Plan: 14

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CLC1 14.7

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: • Previous recommendation: Policy CLC1 (Supporting text 14.7). Future development will also need to consider the possible requirement for a marine licence for works which take place below the mean high-water mark. This should be in consultation with the Marine Management Organisation and with regard to Marine Policy Statement (September 2011) and the East Inshore and East Offshore Marine Plans (April 2014).

Suggested Modifications: Many thanks for inclusion of supporting text around the mean high-water mark. Recommend that supporting text should clearly clarify when marine licensing requirements may be necessary.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP154-181 - Marine Management Organisation (PDF, 254 KB)(opens new window)

Rep ID: 181 / Respondent: Marine Management Organisation Charlotte Lewis

Date Received: 1/24/2025

Section of the Plan:

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:General

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Further comments for consideration throughout the Local Plan:

• Growing offshore energy sector: Given the overlap between boundaries and the cross-cutting nature of offshore energy developments, this theme falls within both of our remits (with reference to our marine plan policies GOV1, WIND1, EC3 and TIDE1).

• Strong tourism industry: Due to the coastal nature of the borough and the tourism brought in by the seafront and beaches, the coastal assets identified in your plan are also referenced in marine plans (marine plan policies GOV1, TR1, TR2 and TR3).

• High unemployment rates and low earnings: This theme is also highlighted within the East Marine Plans, whereby economic factors form a pillar of sustainability (marine plan policies EC1, EC2, EC3).

• Climate change: The impacts of climate change are seen within both the terrestrial and marine environments. Some initiatives identified in your local plan (wind energy) are also covered in the marine plans (WIND1, CC1 and CC2).

• Sensitive landscapes: The two identified sensitive landscapes have elements of marine influence, within which our interested stakeholders overlap.

Suggested Modifications: See Question 5

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP154-181 - Marine Management Organisation (PDF, 254 KB)(opens new window)

Rep ID: 182 / Respondent: Robert Boswell

Date Received: 1/30/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB25

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: OSS 3 : the following objection relates to URB25 for Site S159 to be referred to as EAW

The Policy calls for the avoidance of Urban sprawl and unnecessary loss of Green areas

1. The Plan seeks to destroy an area of natural woodland which provides a prefect habitat for a vast array of wildlife.

This plan would destroy this Forever

2. Also this area contains a vast array of trees (some of which I was advised were of a Protected status) with many varieties of tree, bush and shrub. The collection of flora and fauna living in the area / environmental situation over many years will have interacted in various degrees to form an ecosystem. This plan would destroy it Forever

3. We should also consider the less visible "wildlife" who also would have their long standing habitat and precious home destroyed. I would cite the many examples of where endangered or rare species (for example Bats or Snails and the like) have impacted detrimental development plans.

Suggested Modifications: Remove EAW site S159 under Policy URB25 from the Plans

Request to be heard?: No

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 183 / Respondent: Robert Boswell

Date Received: 1/30/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB25

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons:

The following objection relates to URB25 on the Plan for Site 159 to be referred to here as EAW

OSS1

1. Site159 was only added after Reg 18 Draft and only included in the final Availability Assessment Report in October 2024?

2. URB25 features the development as "70 homes" whereas by this latest AAR Oct24 document it has leapt up by 50% to show a revised total of 103 properties?

3. In the recent past the development EAW has been the subject of total rejection of both Local and National Planning authorities due to myriad of overwhelming issues not least of all safety, danger to children, risk, health & safety, security and the massive decimation of a precious area of green natural land. None of these issues have changed since nor does the Local Plan indicate any progress or ideas for improvement so Why include it here

4. The past Plans for development attempts featured proposals for 79 then 72 houses, Why would a plan for 103 properties be in any way considered as acceptable, desirable or practical. It enhances the past overwhelming negative elements (leading ultimately to rejection) by a further 50%

5. In a reasonable estimate 103 additional houses would generate 200 families with an extra 50 children facing the dangers and risks highlighted in previous planning reviews : Also it could be expected that EAW would face an 250 additional vehicles of varying size etc (eg White Van man, works trucks, "Chelsea Tractors" ) using it is the sole In/ Out access road. As is well known it is already very congested and very dangerous considering the School in the street (over 200 pupils) this Plan would massively increase the dangers & risks.

6. The additional strain on already creaking Services & Infrastructure would be significant almost crippling to an area already overwhelmed by demand. There does seem to be any part of the overall Plan that would in any way ease this pressure.

7. Finally this area is a wonderful natural woodland, greenery, wildlife, and an example of nature's best. In my opinion GYB has a myriad of brownfield options to avoid the ravaging of one the few, rare & precious Green areas and all for another Concrete Jungle.. you are planning to "pave Paradise"

Suggested Modifications: Remove URB25 Site S159 from any part of the Plan

We should seek to preserve this rare and excellent example of nature's best and of course its historical importance to us all in GYB et alone and retain one of the very few Green precious areas we have

Request to be heard?: No

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 184 / Respondent: Robert Boswell

Date Received: 1/30/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB25

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: OSS4 : These comments refer to Policy URB25 Site S159 to be referred to as EAW going forward

1. A proposed development of 103 house could, by a reasonable projection, bring this EAW Area some 250 residents (incl. say 50

children), 150 - 200 vehicles of varying natures and sizes and the eclectic mix of people that any group brings. Just those figures alone show the immediate pressure on the surrounding infrastructure.

2. There appears little in the Local Policy to address the basics needs of such a local area population growth. The only new school mentioned is in Caister, doctors/ dentists are already well over subscribed as an example. The Policy just seems to mention the number of various services eg, 1 x dentist but if such services incl Schools are overwhelmed and therefore unavailable now how can they cope with a new user influx.

3. This brings us to traffic.

EAW experiences daily congestion, associated road rage and inconsiderate parking and high risk on particularly the 3 key times of school drop off/ collection. In past failed plans (local & national planning authority rejections) the clear and obvious constant danger to primarily the 200+ children attending EAW's school was obvious and alarming.

In my view, the highway safety fears and risks arising from this Plan with the inevitable increase of over 150+ vehicles using just 1 x single access road are well documented from the past and acknowledged by all parties including councillors. This traffic will be in addition to the existing residents, the flats next to the school and the "3 visits-per-day" parents of over 200 school children.

The the sole route to the new estate will be past the main entrance of a school!

EAW is constructed to allow the passage of two "standard" vehicles. Any incident in the road; badly parked cars; contractor vans; deliveries; refuse collection or resident visitors (let alone the horrendous volume of construction related traffic during the building period) will bring total chaos to EAW, instant "jams", high potential for total gridlock, restricted access for emergency vehicles, and vastly increased safety risks & issues

4. The mentioned relief / emergency route vis Columb Road is just not feasible in my view, this narrow street also currently suffers from daily congestion and parking issues for residents, it just would not work.

Suggested Modifications: Remove Site S159 from the Plan

Request to be heard?: No

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 185 / Respondent: Norfolk and Waveney Intregrated Care System (ICS) Thomas Clare

Date Received: 1/30/2025

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy OSS4 -

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: 2.0 Existing Healthcare Position Proximate to the Proposed Development Plan Area

2.1 The LDP document covers the administrative area of great Yarmouth.

2.2 Currently, within the administrative area, healthcare provision incorporates a total of 15 GP practices, 1 acute hospital, 8 mental health facilities, 8 community clinics and 3 ambulance stations/response posts. The LDP area also spans across two different PCN's (Primary Care Networks). These are the healthcare buildings available that this Local Development Plan must consider in formulating future strategies.

2.3 Policy OSS4 Infrastructure Provision should recognise all healthcare and ambulance service buildings operated by EEAST as Strategic Infrastructure. This could include services which are located from outside the immediate local plan area, but provide services inside the local plan area (e.g. emergency ambulance services). The following amendments would ensure this is fully recognised in the Great Yarmouth Local Plan:

Amendment to Strategic Infrastructure paragraph (page 14)

"Provision of or redevelopment of strategic healthcare infrastructure, including emergency ambulance services and associated facilities, in accordance with Policy xxx."

Addendum to section 3.21. Strategy for the urban area of Great Yarmouth, Gorleston and Bradwell

(page 16) Great Yarmouth "1 Ambulance Station"

Addendum to paragraph 4.6

Between "South Gorleston hosts the James Paget University Hospital which serves the Borough and beyond to meet a wide variety of healthcare needs." and "Just to the south, is Beacon Park which merging into Bradwell,"

"Ambulance stations serve the borough and beyond to meet emergency healthcare service needs for the resident population and visitors alike as well as urgent and emergency responses to healthcare professionals and blue light colleagues requiring ambulance assistance."

Amendment to Infrastructure 4.13-page (page 28)

"To accommodate growth there is a need to provide improved healthcare provision for the urban area comprising of acute healthcare, intermediate healthcare, primary healthcare, and mental health services" change to

"To accommodate growth there is a need to provide improved healthcare provision for the urban area comprising of acute healthcare, intermediate healthcare, primary & community healthcare, mental health services and the ambulance service."

Amendment to Infrastructure 4.13-page (page 28)

Between "Improvements will include enhanced healthcare facilities at Shrublands" and "and the replacement James Paget University Hospital"

"Improvements will include enhanced healthcare facilities at Shrublands, Gorleston ambulance station and the replacement James Paget University Hospital."

Suggested Modifications: See Question 5

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP185-211 - Norfolk and Waveney Integrated Care System (PDF, 1 MB)(opens new window)

Rep ID: 186 / Respondent: Norfolk and Waveney Intregrated Care System (ICS) Thomas Clare

Date Received: 1/30/2025

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Page 14

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: 2.0 Existing Healthcare Position Proximate to the Proposed Development Plan Area

2.1 The LDP document covers the administrative area of great Yarmouth.

Amendment to Strategic Infrastructure paragraph (page 14)

"Provision of or redevelopment of strategic healthcare infrastructure, including emergency ambulance services and associated facilities, in accordance with Policy xxx."

Addendum to section 3.21. Strategy for the urban area of Great Yarmouth, Gorleston and Bradwell

(page 16) Great Yarmouth

"1 Ambulance Station"

Addendum to paragraph 4.6

Amendment to Infrastructure 4.13-page (page 28)

Between "Improvements will include enhanced healthcare facilities at Shrublands" and "and the replacement James Paget University Hospital"

"Improvements will include enhanced healthcare facilities at Shrublands, Gorleston ambulance station and the replacement James Paget University Hospital."

2.4 Reference to the Infrastructure Needs Study (March 2024) needs to address the omission of Emergency Ambulance Services either under the Health Care or Emergency Services Sections. This may be due to emergency ambulance service being commissioned on behalf of all Integrated Care Systems/Board by Suffolk and North-East Essex ICS and the service requirements therefore were not included in the Norfolk & Waveney ICB document used as a source document.

Suggested Modifications: See Question 5

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP185-211 - Norfolk and Waveney Integrated Care System (PDF, 1 MB)(opens new window)

Rep ID: 187 / Respondent: Norfolk and Waveney Intregrated Care System (ICS) Thomas Clare

Date Received: 1/30/2025

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:3.21

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: 2.0 Existing Healthcare Position Proximate to the Proposed Development Plan Area

2.1 The LDP document covers the administrative area of great Yarmouth.

Amendment to Strategic Infrastructure paragraph (page 14)

"Provision of or redevelopment of strategic healthcare infrastructure, including emergency ambulance services and associated facilities, in accordance with Policy xxx."

Addendum to section 3.21. Strategy for the urban area of Great Yarmouth, Gorleston and Bradwell

(page 16) Great Yarmouth

"1 Ambulance Station"

Addendum to paragraph 4.6

Amendment to Infrastructure 4.13-page (page 28)

Between "Improvements will include enhanced healthcare facilities at Shrublands" and "and the replacement James Paget University Hospital"

"Improvements will include enhanced healthcare facilities at Shrublands, Gorleston ambulance station and the replacement James Paget University Hospital."

Suggested Modifications: See Question 5

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP185-211 - Norfolk and Waveney Integrated Care System (PDF, 1 MB)(opens new window)

Rep ID: 188 / Respondent: Norfolk and Waveney Intregrated Care System (ICS) Thomas Clare

Date Received: 1/30/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:4.6

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: 2.0 Existing Healthcare Position Proximate to the Proposed Development Plan Area

2.1 The LDP document covers the administrative area of great Yarmouth.

Amendment to Strategic Infrastructure paragraph (page 14)

"Provision of or redevelopment of strategic healthcare infrastructure, including emergency ambulance services and associated facilities, in accordance with Policy xxx."

Addendum to section 3.21. Strategy for the urban area of Great Yarmouth, Gorleston and Bradwell

(page 16) Great Yarmouth

"1 Ambulance Station"

Addendum to paragraph 4.6

Amendment to Infrastructure 4.13-page (page 28)

Between "Improvements will include enhanced healthcare facilities at Shrublands" and "and the replacement James Paget University Hospital"

"Improvements will include enhanced healthcare facilities at Shrublands, Gorleston ambulance station and the replacement James Paget University Hospital."

Suggested Modifications: See Question 5

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP185-211 - Norfolk and Waveney Integrated Care System (PDF, 1 MB)(opens new window)

Rep ID: 189 / Respondent: Norfolk and Waveney Intregrated Care System (ICS) Thomas Clare

Date Received: 1/30/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:4.13

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: 2.0 Existing Healthcare Position Proximate to the Proposed Development Plan Area

2.1 The LDP document covers the administrative area of great Yarmouth.

Amendment to Strategic Infrastructure paragraph (page 14)

"Provision of or redevelopment of strategic healthcare infrastructure, including emergency ambulance services and associated facilities, in accordance with Policy xxx."

Addendum to section 3.21. Strategy for the urban area of Great Yarmouth, Gorleston and Bradwell

(page 16) Great Yarmouth

"1 Ambulance Station"

Addendum to paragraph 4.6

Amendment to Infrastructure 4.13-page (page 28)

Between "Improvements will include enhanced healthcare facilities at Shrublands" and "and the replacement James Paget University Hospital"

"Improvements will include enhanced healthcare facilities at Shrublands, Gorleston ambulance station and the replacement James Paget University Hospital."

Suggested Modifications: See Question 5

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP185-211 - Norfolk and Waveney Integrated Care System (PDF, 1 MB)(opens new window)

Rep ID: 190 / Respondent: Norfolk and Waveney Intregrated Care System (ICS) Thomas Clare

Date Received: 1/30/2025

Section of the Plan: 0

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Infrastructure Study -

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: 2.4 Reference to the Infrastructure Needs Study (March 2024) needs to address the omission of Emergency Ambulance Services either under the Health Care or Emergency Services Sections. This may be due to emergency ambulance service being commissioned on behalf of all Integrated Care Systems/Board by Suffolk and North-East Essex ICS and the service requirements therefore were not included in the Norfolk & Waveney ICB document used as a source document.

The omission of emergency ambulance services needs to be corrected within the Infrastructure Needs Study as the increase in population will impact on ambulance stations in and around the area, as well as the regional call centres. In particular expansion of specialist housing for older people as identified in Policy OSS1 and Policy HOU5.

EEAST's activity data demonstrates that in addition to call volume, the age profile of residents impacts on demand for emergency ambulance services. People at both ends of the age spectrum consume a disproportionately large quantity of healthcare services and resource:

• Over 75s are most likely to have multiple long-term conditions and complex care needs

• Analysis of EEAST activity from 2019/20 indicates residents Aged 65 years and over account for over 1/3 (35%) of Category 1 ambulance activity and 52% of all activity.

Suggested Modifications: See Question 5

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP185-211 - Norfolk and Waveney Integrated Care System (PDF, 1 MB)(opens new window)

Rep ID: 191 / Respondent: Norfolk and Waveney Intregrated Care System (ICS) Thomas Clare

Date Received: 1/30/2025

Section of the Plan: 7

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HOU5 -

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Appendix 2 includes design principles for new build specialised housing and should be incorporated to relevant housing policies, e.g. Policy HOU5 Housing for Older People and Policy HOU9 Accessibility Standards. Appendix 3: EEAST Health & Wellbeing and Scheme Design Measures

Health and Wellbeing The following elements support physical, mental health and wellbeing and help develop community cohesion:

• Since the COVID-19 pandemic more people are likely to work from home for at least part of the week, the room size and layout should be sufficient to facilitate at least one person working from home in a suitable environment as this supports both physical and mental health and wellbeing. Access to fresh air is also recommended.

• Developers' inclusion of community gardens, allotments, orchards, meadow flower and woodland planting areas. Balconies, roof gardens and terraces also provide green space opportunities in apartment buildings. Consideration of all senses (sight, hearing, touch, smell, taste) should be addressed by the developer in the planting plan and use of local flora and fauna and wildlife corridor connection.

• In central open space developers should establish of seating in open spaces and along walkways to provide the opportunity for residents to meet and supports those who have limited mobility to rest and enjoy the surrounding green space.

Care Homes - At least one emergency lifting devices with a preference of one per floor. These inflating devices are designed to lift the frailest individual up to a bariatric patient from the floor in a safe and dignified manner minimising the risk of injury to both the fallen individual and the person lifting them. This device will enable care home staff to aid uninjured residents back into their chair/bed and thereby reduce the number of attendances from ambulance service.

At least one Automated External Defibrillator should be installed with a preference of one per floor.

Parking space of for at least one emergency ambulance and one patient transport vehicle is provided close to the entrance (minimum 10.6m in length and 4m in width) ideally with 2 EV charging points.

Lifts - Lifts should be of a suitable size to enable a patient to be safely transported by stretcher and accompanied by 2 medical personnel alongside the stretcher (a minimum internal of 2.6m x 1.6m is required. The lift should be fire-proofed to the appropriate standard to ensure evacuation during a fire or other emergency situation. Flood Assessments Flooding significantly affects residents physical and mental health in both the short and long term. Developers to utilise the catchment of clean/grey water to include underground storage tanks or multiple water butts (i.e. garage and house) to help reduce the risk of localised flooding post development. There is the potential for residents to reuse water for gardens, car washing and in community gardens instead of entering main sewers.

The use of sustainable urban drainage through permeable paving in driveways and parking areas to accommodate surface water run-off is welcomed and should be suitable for use by wheelchairs, mobility scooters and pushchairs.

In Flood Zones 2 and 3 EEAST request the appropriate the use of swales and other drainage measures to absorb any flood waters and would urge developers ensure measures are taken to minimise the risk of flooding in surrounding areas as well as flood proofing homes, garages and other infrastructure.

Transport, Design and Access - Cycle parking should allow for several types of cycles (e.g. trike, electric bike or mobility scooter) to be stored, covered, secure and well lit.

Blue light emergency services would request developers support the Vision Zero/Safe System approach to design out road accidents for vehicle occupants, motorcyclists, bicyclists and pedestrians by utilising clear lines of sight, use of appropriate street/road lighting, use the of village gateways on approach to the junctions/roundabout and other opportunities to support speed reduction. Clear lines of sight are retained close to properties and walkways to support the reduction and fear of crime whilst also minimising the impact of artificial light.

Suggested Modifications:

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP185-211 - Norfolk and Waveney Integrated Care System (PDF, 1 MB)(opens new window)

Rep ID: 192 / Respondent: Norfolk and Waveney Intregrated Care System (ICS) Thomas Clare

Date Received: 1/30/2025

Section of the Plan: 7

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HOU9 -

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons:

Appendix 2 includes design principles for new build specialised housing and should be incorporated to relevant housing policies, e.g. Policy HOU5 Housing for Older People and Policy HOU9 Accessibility Standards. Appendix 3: EEAST Health & Wellbeing and Scheme Design Measures

Health and Wellbeing The following elements support physical, mental health and wellbeing and help develop community cohesion:

At least one Automated External Defibrillator should be installed with a preference of one per floor.

Parking space of for at least one emergency ambulance and one patient transport vehicle is provided close to the entrance (minimum 10.6m in length and 4m in width) ideally with 2 EV charging points.

Transport, Design and Access - Cycle parking should allow for several types of cycles (e.g. trike, electric bike or mobility scooter) to be stored, covered, secure and well lit.

Suggested Modifications: See Question 5

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP185-211 - Norfolk and Waveney Integrated Care System (PDF, 1 MB)(opens new window)

Rep ID: 193 / Respondent: Norfolk and Waveney Intregrated Care System (ICS) Thomas Clare

Date Received: 1/30/2025

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy OSS4 -

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: 3.1 In progressing the Great Yarmouth Local Development Plan, care should be taken to ensure that emerging policies will not have an adverse impact on healthcare provision within the plan area and over the plan period.

3.2 In instances where major policies involve the provision of development in locations where healthcare infrastructure capacity is insufficient to meet the augmented needs, appropriate mitigation will be sought.

3.3 Policies should be explicit in that contributions towards healthcare provision will be obtained via S106 or CIL and the Local Planning Authority will consider a development's sustainability with regard to effective healthcare provision.

3.4 The exact nature and scale of the contribution and the subsequent expenditure by partners will be calculated at an appropriate time as and if schemes come forward over the plan period to realise the objectives of the LDP.

3.5 Plans and policies should be revised to ensure that they are specific enough in their aims, but are not in any way prescriptive or binding on the ICS Strategic Estates and EEAST's estate strategy to create a Hub and Spoke network of ambulance stations, to carry out certain development within a set timeframe, and do not give undue commitment to projects.

3.10 Notwithstanding this, there should be a reasonably worded policy within the emerging LDP that indicates a supportive approach from the Local Planning Authority to the improvement, reconfiguration, extension or relocation of existing medical facilities.

Suggested Modifications: See Question 5

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP185-211 - Norfolk and Waveney Integrated Care System (PDF, 1 MB)(opens new window)

Rep ID: 194 / Respondent: Norfolk and Waveney Integrated Care System (ICS) Thomas Clare

Date Received: 1/30/2025

Section of the Plan: 12

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HEC1 -

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: 3.6 Policy HEC1 Health Environments states a Health Impact Assessment for developments of 150 dwellings or more, or 5 hectares or more and proposals which include 50 or more retirement, extra care/sheltered housing require an HIA. This HIA should assess the potential impact on all healthcare infrastructure including primary, acute, community, mental health and ambulance facilities

Suggested Modifications: None

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP185-211 - Norfolk and Waveney Integrated Care System (PDF, 1 MB)(opens new window)

Rep ID: 195 / Respondent: Norfolk and Waveney Integrated Care System (ICS) Thomas Clare

Date Received: 1/30/2025

Section of the Plan: 12

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HEC2 -

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: 3.7 Policy HEC2 Open space provision for new housing development - these proposals are welcomed and the ICS would urge the Local Plan includes the suggestions made by EEAST located in Appendix 3 are added to this policy as they support the health and well- being of residents and visitors to the area.

Suggested Modifications: It was suggested that the policy should include reference to specific health and wellbeing design measures; including:

• Range of open spaces e.g. community gardens, allotments, orchards, meadow flower and woodland planting areas

• Planting of local flora and fauna and wildlife connections for sensory benefits

• Include seating in open spaces to support those who have limited mobility.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP185-211 - Norfolk and Waveney Integrated Care System (PDF, 1 MB)(opens new window)

Rep ID: 196 / Respondent: Norfolk and Waveney Intregrated Care System (ICS) Thomas Clare

Date Received: 1/30/2025

Section of the Plan: 14

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CLC2 -

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: 3.8 Policy CLC2 - Flood Risk - emergency services respond to incidents of flooding and therefore support prevention and mitigation measures as outlined in the Sustainable Drainage Systems (SuDS) and recommendations identified in Appendix 3. In addition, there can be long term impacts on residents physical and mental health and wellbeing following incidents of flooding which can impact on all healthcare providers. Therefore, no healthcare provider facilities or care/nursing home facilities should be located in Flood Zone 2 or 3 areas. These aspects should be incorporated in CC5 and CC6 of the Design Code.

Suggested Modifications:

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP185-211 - Norfolk and Waveney Integrated Care System (PDF, 1 MB)(opens new window)

Rep ID: 197 / Respondent: Norfolk and Waveney Intregrated Care System (ICS) Thomas Clare

Date Received: 1/30/2025

Section of the Plan: 13

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy SUT1 -

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Transport Assessment and Travel Plan - these should include the potential impact, accessibility and time taken for emergency services to respond to incidents. Whilst each emergency service has different response times they are required to achieve, a minute's

delay is significant for each service. Therefore, restricted access due to tight turning points, congestion, narrow roadways (e.g. due to parked vehicles) or pedestrian only access between neighbourhoods can significantly impact on preservation of life and buildings. Engagement with emergency services is strongly recommended.

Suggested Modifications:

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP185-211 - Norfolk and Waveney Integrated Care System (PDF, 1 MB)(opens new window)

Rep ID: 199 / Respondent: Norfolk and Waveney Intregrated Care System (ICS) Thomas Clare

Date Received: 1/30/2025

Section of the Plan: 14

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CLC4 -

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: 3.11 The ICS together with healthcare service providers are mandated to achieve NHS Carbon Reduction Plan, Net Zero Commitment, NHS Net Zero Travel and Transport Strategy and would seek support from the Local Plan via s106/CIL opportunities to increase the level of renewable and low-carbon energy at existing and future healthcare facilities. Support in recognising this need through policies such as Policy CLC4 Renewable and Low-Carbon Energy Development, Policy CLC6 - Energy Efficiency for New Developments, Policy CLC7 - Energy Efficiency and Embodied Carbon of Existing Buildings.

Suggested Modifications: None

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP185-211 - Norfolk and Waveney Integrated Care System (PDF, 1 MB)(opens new window)

Rep ID: 200 / Respondent: Norfolk and Waveney Intregrated Care System (ICS) Thomas Clare

Date Received: 1/30/2025

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy OSS4 -

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Suggested Modifications: None

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP185-211 - Norfolk and Waveney Integrated Care System (PDF, 1 MB)(opens new window)

Rep ID: 201 / Respondent: Norfolk and Waveney Intregrated Care System (ICS) Thomas Clare

Date Received: 1/30/2025

Section of the Plan: 14

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CLC7 -

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Suggested Modifications: None

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP185-211 - Norfolk and Waveney Integrated Care System (PDF, 1 MB)(opens new window)

Rep ID: 202 / Respondent: Norfolk and Waveney Intregrated Care System (ICS) Thomas Clare

Date Received: 1/30/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT1 -

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: 3.12 Policy NAT1 - Protecting Biodiversity and Geodiversity, Policy NAT9 - Dark Skies and Policy NAT10 - Trees, Woodlands, and Hedgerows - the ICS welcomes these proposals to support the physical and mental health and wellbeing of residents and visitors and the ICS would urge the Local Plan includes the suggestions made by EEAST located in Appendix 2 is added to this policy as they support the health and wellbeing of residents and visitors to the area.

Suggested Modifications: Appendix 2 attached

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP185-211 - Norfolk and Waveney Integrated Care System (PDF, 1 MB)(opens new window)

Rep ID: 203 / Respondent: Norfolk and Waveney Intregrated Care System (ICS) Thomas Clare

Date Received: 1/30/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT9 -

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Suggested Modifications: Appendix 2 attached

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP185-211 - Norfolk and Waveney Integrated Care System (PDF, 1 MB)(opens new window)

Rep ID: 204 / Respondent: Norfolk and Waveney Intregrated Care System (ICS) Thomas Clare

Date Received: 1/30/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT10 -

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Suggested Modifications: Appendix 2 attached

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP185-211 - Norfolk and Waveney Integrated Care System (PDF, 1 MB)(opens new window)

Rep ID: 205 / Respondent: Norfolk and Waveney Intregrated Care System (ICS) Thomas Clare

Date Received: 1/30/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:4.13 4.263

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: 3.16 Strategy for the urban area of Great Yarmouth, Gorleston and Bradwell:

Policy URB1 through to URB27 focus entirely on the main urban areas of Great Yarmouth, Gorleston and Bradwell. Section 4.13 of the Urban strategy states that there will be a need for improved healthcare provision for this large area and that this need will be accommodated through the new community infrastructure levy (CIL). The ICB supports and welcomes this statement on behalf of healthcare infrastructure. Improvements planned for the area include the Shrublands health centre and the planned new hospital programme to replace the James Paget Hospital.

3.17 Total proposed housing numbers from new and existing sites for these areas total 2923. The net gain in population from these dwellings is circa 5,539. This results in the need for an additional 346.7 sqm of Primary care floorspace. Without appropriate mitigation this will place unsustainable pressure on healthcare premises and therefore services for the population of the urban area.

3.18 Policies URB4 to URB9 are in relation to Great Yarmouth only. Where these policies include residential dwellings this totals 540-660 homes from new sites, when existing sites are also added to this the total comes to 942 homes. Modelling indicates that this would result in a circa 1,785 net gain in population resulting in a need for circa 111.6 of primary care floorspace. As and when planning applications are submitted for these sites, the ICS will assess the status of the local healthcare infrastructure and request mitigation through S106 or CIL if this is in place at the time.

3.19 Policies URB10, URB11, URB 21 & URB 25 relate to the Gorleston area. The number of proposed new dwellings for Gorleston is 845 and 1,010 with the addition of existing sites included in the local plan timeframe. This translates to a net population gain of circa 1,915 residents and a requirement for circa 120 sqm of additional floorspace for Primary care services. As above, mitigation will be applied for where required through S106 or CIL when planning applications come forward.

It is acknowledged that policy URB 24 is in support of the provision of a new healthcare facility to meet the current and future needs of the community. Currently housed in a temporary building, this policy will allow for new healthcare provision on site which would go some way to mitigating the increase in population and impact on healthcare services in that area.

3.20 The remaining urban policies URB19 & URB26 which include residential dwellings are for the area of Bradwell. The two policies proposed will aim to deliver 450 dwellings as new allocations and a total of 971 dwellings when combined with existing sites for this plan period. A total increase of circa 1,839 in terms of net gain in population has been modelled resulting in a need for circa 115 sqm of additional primary care floorspace, which would be required to be funded from S106 or CIL as a means of mitigation.

Suggested Modifications:

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP185-211 - Norfolk and Waveney Integrated Care System (PDF, 1 MB)(opens new window)

Rep ID: 206 / Respondent: Norfolk and Waveney Intregrated Care System (ICS) Thomas Clare

Date Received: 1/30/2025

Section of the Plan: 5

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:5.8

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: 3.21 Strategy for Caister-on-Sea:

Section 5.8 of the Caister-on-Sea strategy states that there is a need to provide improved healthcare provision for the urban area and that a new Healthcare centre is proposed on the consented scheme to the West of Jack Chase Way.

3.22 Policy CAS1 is an extension to the already approved Jack Chase Way development, as detailed above healthcare has secured S106 from this initial development to be used towards a new healthcare centre. Should the additional 1,100 houses come forward, further financial developer contributions will be required towards healthcare as acknowledged in Policy CAS1 page 104 of the local plan. Policy CAS2 proposes 40 units of sheltered housing / housing with care, this type of residential dwelling brings its own specific impacts to healthcare as those likely to take up residence already require more care which places further strain on GP's, District Nurses, Emergency ambulance services and the acute hospitals, early discussions will be required with all parties to ensure this development is sustainable and serviceable by healthcare. The new allocations for Caister have indicative figures of circa 1,554 dwellings from existing and new allocations which translates to circa 184 sqm of primary healthcare space resulting from a net gain in population of circa 2,944 residents.

Suggested Modifications: N/A

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP185-211 - Norfolk and Waveney Integrated Care System (PDF, 1 MB)(opens new window)

Rep ID: 207 / Respondent: Norfolk and Waveney Intregrated Care System (ICS) Thomas Clare

Date Received: 1/30/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy RUR1 -

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: 3.23 Strategy for Rural Areas:

The policies within the rural area strategy account for 35% of the planned housing growth, which is in accordance with Policy OSS1. Most of this development is planned for the larger villages, however there will still be growth in the smaller villages and the cumulative impact of these proposed developments need to be taken into consideration.

Policy BEL1 indicates that Belton would benefit from additional community facilities and acknowledges there is a need to provide improved healthcare provision for the area. The Millwood Partnership is the closest GP primary healthcare provider to Belton and would likely see most of the impact from the allocated 100 dwellings further to the proposed housing allocations in Bradwell as indicated in policies URB19 & URB26. Overall there is 109 dwellings proposed for Belton including new and existing site allocations, this equates to a net gain in population of circa 204 residents and a requirement for 12.8 sqm of floorspace for primary care alone.

3.24 Policy BUR1 in relation to growth in Burgh Castle has a small number of dwellings proposed at 20, however due to the proximity of Burgh Castle to Belton and Bradwell this would add to the cumulative total of new dwellings, with no healthcare infrastructure located in Burgh castle or Bradwell, these residents are likely to travel to Bradwell for healthcare needs, which is currently serviced by the Millwood Partnership. Mitigation via S106 or CIL would be needed to ensure a sustainable level of healthcare is provided that services Burgh Castle, Belton and Bradwell. Such mitigation will be requested as and when planning applications are submitted.

3.25 Similar to Burgh Castle policy FLG1 for Fleggburgh proposes 20 dwellings, however there is also an existing allocation of 23 dwellings creating a total of 43 additional dwellings. Fleggburgh has its own GP surgery, however this is already constrained in terms of patients for the size of the infrastructure. The additional 43 dwellings will result in circa 78 additional residents, although a small amount of growth this will place further constraint on healthcare premises. As above any required mitigation will be accessed through S106 or CIL.

3.36 Hemsby is proposed to have growth of 434 dwellings from existing and new developments during this plan period. HEM1 allocates 206 new dwellings with remainder made up of existing allocations. Hemsby has its own GP Branch in the village, and it is noted that healthcare is included in the infrastructure section 6.58 acknowledging potential improved healthcare provision if required. Estimated requirements indicate the need for 32 sqm of primary care floorspace to accommodate the modelled 349 additional residents. It should also be noted that coastal areas are likely to see a surge in tourism during the summer months which could also impact surgeries located in these areas.

3.37 This local plan has allocated two sites in Hopton-on-Sea, policy HOP1 for 50 units of elderly accommodation (sheltered/housing with an element of care) and the other HOP2 for 66 dwellings (40 standard and 26 sheltered/housing with an element of care), further to this there are another 99 existing allocations for Hopton-on-Sea totalling 215 proposed dwellings with a net gain in population of 404 residents and circa 25.3 sqm of primary care floorspace required. As with all coastal areas consideration needs to be given to the seasonal tourism influx and the impact this will have on healthcare services in the area. With regards to elderly accommodation/housing with care, this will place further pressure on local healthcare as this demographic tends to require more healthcare professional contacts and a higher rate of ambulance call outs and conveyances. It is recommended that the local planning authority liaise with the East of England Ambulance service with regards to requirements at such facilities, this may include adequate space and turning circle for emergency vehicles, lift size to accommodate stretchers and staff, and lifting aids with trained staff etc.

3.38 Ormesby St Margaret has 3 housing developments proposed in the local plan (policies ORM1, ORM2 and ORM3), these proposed allocations would result in 357 dwellings in addition to the existing allocations being carried forward in to the plan resulting in an overall total of 422 dwellings. There is also a smaller allocation of 66 dwellings proposed for nearby Scratby which needs to be taken into account from a cumulative perspective, modelling indicates a net gain in population of circa 920 residents along with a requirement of 58 sqm of primary care floorspace to manage the additional population growth. There is reference to increasing healthcare provision in the local plan for Ormesby St Margaret, and whilst this may not be an immediate requirement demand and capacity figures will fluctuate over the local plan period.

3.39 For Martham Policies MAR1 to MAR6 include new residential dwelling allocations which amount to a total of 514 dwellings, include the existing allocations carried forward to this local plan the overall total is 678 dwellings. Martham is a rural area with its own GP practice, however continued growth in the area will soon start to impact any capacity the practice has. Based on the total number of dwellings, the net gain in population has been estimated at 1,284 residents which would require circa 90 sqm of primary care floorspace. As with all the main rural villages, mitigation against the developments will be sought when required via S106 or CIL.

Suggested Modifications: 3.40 Further to the above requirements, consideration should also be given to the smaller village cluster developments that fall below the planning in health protocol criteria for engagement with the ICS strategic estates team and the cumulative effect that these smaller developments can have on existing healthcare infrastructure.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP185-211 - Norfolk and Waveney Integrated Care System (PDF, 1 MB)(opens new window)

Rep ID: 208 / Respondent: Norfolk and Waveney Intregrated Care System (ICS) Thomas Clare

Date Received: 1/30/2025

Section of the Plan: 7

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HOU9

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: 3.41 The ICS Strategic Estates team supports the requirements in Policy HOU9 that all new housing should be built to enhanced accessibility standards to cater for people's changing circumstances through life. This will provide the opportunity for residents to stay in their home rather than in a healthcare environment.

Suggested Modifications:

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP185-211 - Norfolk and Waveney Integrated Care System (PDF, 1 MB)(opens new window)

Rep ID: 209 / Respondent: Norfolk and Waveney Intregrated Care System (ICS) Thomas Clare

Date Received: 1/30/2025

Section of the Plan: 7

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HOU5 -

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: 3.42 Policy HOU5 is specific to housing for older people. Where any housing that falls under sheltered/supported housing, extra care housing and residential/nursing care homes, it is encouraged that early discussions are sought with the Integrated Care Board (ICB) and the Emergency Ambulance Service (EEAST) along with Borough and Norfolk County Council to ensure a fully joined up approach. We would request that supporting text is added to this section with the above in mind.

Suggested Modifications:

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP185-211 - Norfolk and Waveney Integrated Care System (PDF, 1 MB)(opens new window)

Rep ID: 210 / Respondent: Norfolk and Waveney Integrated Care System (ICS) Thomas Clare

Date Received: 1/30/2025

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy OSS4 -

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: There is also the issue around staffing, where there is often shortage of healthcare professional in rural areas, which can lead to longer waiting times and access to care. Also as mentioned previously in section 2, health inequalities and deprivation in rural areas mean residents face unique challenges, addressing these issues will require targeted policies and investment to improve accessibility and enhancing healthcare access.

Suggested Modifications:

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP185-211 - Norfolk and Waveney Integrated Care System (PDF, 1 MB)(opens new window)

Rep ID: 211 / Respondent: Norfolk and Waveney Integrated Care System (ICS) Thomas Clare

Date Received: 1/30/2025

Section of the Plan: 1

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:General -

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: 4.1 This response follows a consultation by Great Yarmouth Borough Council on the Reg 18 Great Yarmouth First Draft Local.

4.2 In its capacity as responding on behalf of health partners in Norfolk and Waveney, the ICS Strategic Estates team has requested that the Local Planning Authority identifies policies and strategies that are considered to directly or indirectly impact upon healthcare provision and has responded with recommendations as to how policy should be shaped in the future.

4.3 Assuming the recommendations are incorporated wholly within the future LDP then the ICS Strategic Estates team would not which to raise an objection to the Great Yarmouth Reg 19 Draft Local Plan.

4.4 The ICS Strategic Estates team has also identified potential shortfalls in infrastructure capacity at existing premises. Healthcare provision across all health sectors needs to be acknowledged within the emerging Local Plan and references made to accessing CIL

funding when required to address the impacts of development on health infrastructure and to ensure timely cost-effective delivery of necessary infrastructure improvements, in the interests of pursuing sustainable development.

Suggested Modifications: 4.5 The recommendations set out above are those that the ICS Strategic Estates team deem appropriate having regard to the projected needs arising from the Great Yarmouth Draft Local Plan.

4.6 Within the draft local plan document there is reference to the Infrastructure study request 2024. The ICS strategic estates team responded to this on the basis of the number of dwellings provided at that time. The new draft local plan has an increase in housing numbers since the Infrastructure study request taking in to account existing allocations carried forward into this plan period and new allocations (appendix 8 of the local plan), therefore the information in the 2024 Infrastructure Study request will be different to the latest modelling for the new housing allocation numbers.

New housing numbers and increased build costs will result in the infrastructure study request figures now being out of date, updated estimated costs will be provided in response to the individual planning applications that may come forward for these sites. A breakdown of costs can be provided to Great Yarmouth Borough Council on request.

4.7 The Ambulance Service, EEAST, have raised concerns in relation to their omission from the text regarding healthcare services. EEAST's full response can be found in appendix 2.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP185-211 - Norfolk and Waveney Integrated Care System (PDF, 1 MB)(opens new window)

Rep ID: 212 / Respondent: Norse Group on behalf of Norfolk County Council Children's Services

Date Received: 1/30/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT3

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Policy NAT3 requiring 20% BNG for major planning applications is not considered to be sound for school sites as it would not be consistent with other policies in the Local Plan and NPPF which support the expansion of schools. The policy has not been fully considered in relation to the impact of providing 20% BNG on existing school sites or in relation to viability with regard to off site contributions. The policy would have a detrimental impact upon the operation and delivery of education and would not be effective.

Suggested Modifications: Norfolk County Council (NCC) Children's Services would not support Policy NAT3 which requires 20% BNG on major planning applications outside of the main settlements and allocated sites as this would prejudice the future operation of school sites. The mandatory requirement for 10% BNG for planning applications introduced in February 2024 has been very difficult to achieve on school sites without impacting upon playing field provision and children's play space. In future this will likely cause conflict with Sport England as a statutory consultee as schools undergo the necessary expansion and the amount of unusable open space/playing field for BNG areas runs out.

An additional 10% for major applications (20% in total) will further reduce the ability for schools to expand and operate effectively and add additional management and maintenance costs over a 30 year period. In time the BB105 requirements would not be met in terms of required areas for soft/hard play and playing field. Whilst the policy suggests the non-statutory additional 10% could be provided off-site, this may result in the County having to enter into a lengthy s106 agreement process to secure the off-site units, spend additional money to purchase BNG units or in worst-case scenario, require the purchase of Statutory BNG Credits at high cost. These additional costs would reduce the funding for children's education and delay projects to find a feasible solution, which would have a detrimental impact on educational delivery.

The Local Plan Viability Assessment (2023) which informs the BNG Policy NAT3 has also not considered the 20% BNG requirement in relation to the viability of school sites so cannot be justified.

We would request that all school sites be an exception to the 20% BNG requirement.

Request to be heard?: Yes

Reason for Request to be heard:To ensure that this is thoroughly considered and to have the opportunity to address further comments on this.

Attachments: N/A

Rep ID: 213 / Respondent: Norse Group on behalf of Norfolk County Council Corporate Property Team

Date Received: 1/30/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HOP1

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: The policy is not considered to be sound because it restricts potential for housing development on neighbouring land which may be required to meet the new NPPF requirements.

The policy does not account for meeting the needs of other groups such as assisted living.

Suggested Modifications: The draft Local Plan proposes to allocate 2.8 hectares of land for 50 units of elderly accommodation. Norfolk County Council as landowner would support the use of the site for 50 units of elderly accommodation in principle. However, we would request the type of accommodation be opened up to other groups including assisted living etc.

We would also request changes to the wording of the policy so the site allocation does not prejudice the future development of land to the south for further housing development to meet local housing need and meet additional housing requirements as a result if changes to the NPPF (December 2024). We would request the 'significant' landscape belt to the south to be removed or reworded to allow landscaping, to help screen the development but not prevent future expansion.

Request to be heard?: Yes

Reason for Request to be heard:To ensure that this is thoroughly considered and to have the opportunity to address further comments on this.

Attachments: N/A

Rep ID: 214 / Respondent: Norse Group on behalf of Norfolk County Council Corporate Property Team

Date Received: 1/30/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB24

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: We consider the policy to be unsound as it may not be effective as it has not considered whether the scheme is viable without an element of affordable/sheltered or market housing which may affect deliverability.

Suggested Modifications: The draft Local Plan allocation URB24 continues to propose a mixed-use scheme comprising healthcare facilities, community facilities and an ancillary element of housing with care. We would repeat our request that the policy allows an element of affordable/sheltered housing or market housing to enhance viability.

Request to be heard?: Yes

Reason for Request to be heard:To ensure that this is thoroughly considered and to have the opportunity to address further comments on this.

Attachments: N/A

Rep ID: 215 / Respondent: Norse Group on behalf of Norfolk County Council Corporate Property Team

Date Received: 1/30/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT8

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: The policy is not sound as it would restrict the potential for deliverable housing development adjacent to Hopton-on-Sea to meet future housing demand in Hopton/the Borough. This is particularly in relation to the new NPPF (December 2024) Chapter 5 and increased housing targets.

Suggested Modifications: Norfolk County Council (NCC) would seek amendments to the policy regarding strategic gaps between Gorleston-on-Sea and Hopton-on-Sea and Hopton-on-Sea and Corton. This restrictive policy would negatively impact housing development on NCC land which may be required to meet additional housing need through the revised NPPF.

Policy NAT8 is seeking a strategic gap between Hopton-on-Sea and Corton and Gorleston-on-Sea and Hopton-on-Sea to prevent development which would significantly reduce the physical gap.

NCC have land to the south and north of Hopton-on-Sea which would be suitable for residential development should there be a need to expand the village in the future (while still retaining a significant gap between settlements). NCC would, therefore, support the policy to avoid the coalescence of settlements in principle, provided there is flexibility to allow modest growth to Hopton in the future (subject to need) which would not significantly reduce the size and effectiveness of the gaps.

NCC has promoted agricultural land abutting the development boundary to the north of Hopton for development as this would form a natural extension to Hopton to meet future housing need without compromising a strategic gap between the developments which could be retained. Policy NAT8 would limit the potential for expansion of Hopton in the future.

We would also object to the supporting text to Policy HOP1 concerning land to the south of Hopton, which limits development to the northern part of the site away from the high-pressure gas main and requires the provision of a landscaping belt which will help preserve the gap in perpetuity from the Great Yarmouth side. We would request this be removed to allow the opportunity for future housing development to be considered to help meet local housing need required by the NPPF (December 2024) or future housing requirements of Hopton.

Request to be heard?: Yes

Reason for Request to be heard:To ensure that this is thoroughly considered and to have the opportunity to address further comments on this.

Attachments: N/A

Rep ID: 216 / Respondent: Norfolk and Waveney Integrated Care System (ICS) Thomas Clare

Date Received: 1/30/2025

Section of the Plan: 0

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Infrastructure Study

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Reference to the Infrastructure Needs Study (March 2024) needs to address the omission of Emergency Ambulance Services either under the Health Care or Emergency Services Sections. This may be due to emergency ambulance service being commissioned on behalf of all Integrated Care Systems/Board by Suffolk and North-East Essex ICS and the service requirements therefore were not included in the Norfolk & Waveney ICB document used as a source document.

Suggested Modifications: Reference to the Infrastructure Needs Study (March 2024) needs to address the omission of Emergency Ambulance Services either under the Health Care or Emergency Services Sections. This may be due to emergency ambulance service being commissioned on behalf of all Integrated Care Systems/Board by Suffolk and North-East Essex ICS and the service requirements therefore were not included in the Norfolk & Waveney ICB document used as a source document.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP185-211 - Norfolk and Waveney Integrated Care System (PDF, 1 MB)(opens new window)

Rep ID: 217 / Respondent: Tom Dawkins

Date Received: 1/30/2025 4:27:00 PM

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB25

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Hello!

I read this article on BBC:

https://www.bbc.co.uk/news/articles/cm2377eymlxo

About the plans to develop housing on a site of woodland.

There is plenty of brown field site around the Great Yarmouth area.

We need to be protecting our nature and wildlife, not destroying it.

How is this plan environmentally friendly? It isn;t.

Suggested Modifications: Do not build on beautiful woods !

Request to be heard?: No

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 218 / Respondent: White & Sons on behalf of Gillian Kittle

Date Received: 1/30/2025 4:36:00 PM

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy MAR1

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: This policy provides for 35% of housing development within the rural areas and specifically at the larger villages such as Martham. This policy is supported and is considered to be positively prepared and effective in securing the viability and sustainability of rural villages. The policy provides for limited growth to meet the needs of rural communities.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 219 / Respondent: White & Sons on behalf of Gillian Kittle

Date Received: 1/30/2025 4:36:00 PM

Section of the Plan: 7

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HOU5

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: This policy is considered to be positively prepared and consistent with national planning policy.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 220 / Respondent: White & Sons on behalf of Gillian Kittle

Date Received: 1/30/2025

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy OSS1

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: The policy provides for 6,640 homes over the plan period 2024-2041 (based on an assessed need under the previous standard method of 6,460 homes - 380 per annum). This is a significant reduction from the 7,500 homes identified in the Regulation 18 consultation, at a time when the Government is seeking to increase housing supply and delivery. The plan is therefore not positively prepared in this regard and the approach of not meeting the actual housing needs is unjustified.

Paragraph 234 of the NPPF 2024 sets out transitional arrangements where plans can be assessed under the 2023 NPPF as opposed to the 2024 NPPF as follows:

"a . the plan has reached Regulation 1982 (pre-submission stage) on or before 12 March 2025, and its draft housing requirement meets at least 80% of local housing need" (using the 2024 NPPF standard method) or

b "the plan has been submitted for examination under Regulation 2284 on or before 12 March 2025..."

It is accepted that the Regulation 19 consultation has taken place in advance of 12th March 2025. However, it does not fulfil the requirement to meet 80% of the housing need assessed under the 2024 NPPF Standard Method. The actual need is 8,925 dwellings (525 per annum) with the proposed housing (6,460) meeting just 72% of this need. In this context the examination should be carried out under the 2024 NPPF.

Whilst the Council intends to submit the plan for examination under Regulation 22 in either February/March according to the Local Development Scheme, it remains to be seen whether the actual submission will be on or before 12th March 2025. If it is not submitted by this date, or it is submitted but fails to meet the relevant legislative requirements for submission, the plan should be considered against the 2024 NPPF, with the consequence that the larger housing requirement must be planned for.

It will be essential for the submitted plan and evidence base to demonstrate that sufficient regard has been had to the Regulation 19 consultation responses, prior to submission for examination, to ensure that due process has been followed with effective consultation and stakeholder engagement. It is questionable if this is achievable given the short period of time between this Regulation 19 consultation concluding on 31st January 2025, should submission be made by 12th March 2025

Suggested Modifications: The housing provision should be increased to reflect the needs of the community.

Request to be heard?: Yes

Reason for Request to be heard:To make representations to the Inspector and inform the debate in relation to this issue.

Attachments: N/A

Rep ID: 221 / Respondent: White & Sons on behalf of Gillian Kittle

Date Received: 1/30/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy MAR5

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Our client is supportive of the allocation at MAR5 which is considered to be one of most suitable sites for new development. Paragraph 6.154 recognises that the village would benefit from housing growth to sustain the existing "large range of services and facilities". The site is contiguous with the settlement boundary of Martham on two sides with access to the Hemsby Road which has a straight orientation providing good visibility in either direction. The land is considered to be suitable, available and deliverable with advanced discussions being held with a new development promoter following a previous option agreement lapsing. The allocation is considered to be justified and effective in meeting the elderly housing needs of residents in Martham and the surrounding area identified within Policy OSS1 and Policy HOU5.

It is considered however that there is the opportunity for additional adjacent land to the east and south to be included within the allocation, for open market and affordable housing, given the sustainable location and the fact that Martham is described as "the largest Primary Village". The new prospective development promotor has expressed a strong interest in this land being included as part of the allocation, highlighting that this will help fund the works to deliver the access which involve abnormal engineering of land levels. I include a plan below showing the additional land promoted for inclusion with the allocation outlined in red. The additional land which it is submitted could be included within the allocation would assist the Council in being able to deliver a level of housing which is closer to the actual need (based on the 2024 Standard Method for calculating the need) and should the Inspector consider that a higher level of provision be required. This would help ensure that the plan is positively prepared and consistent with national policy.

The promoted land extends to approximately 5.2 hectares (in addition to the 0.8 hectares currently within MAR5.) The land in question is within the same family ownership and is therefore available for development now. The additional land would form a natural progression in the extension of the village following on from the previous allocation/development on the northern side of Hemsby Road. Similar to the proposed allocation the land would be considered suitable for development and is in a sustainable location with good access to services in the defined Martham Local Centre.

There are no significant constraints to development of the land. The land is outside of Flood Zones 2 and 3 and without there being any significant surface water drainage issues. There are no heritage assets close to the site which would form a constraint to development.

It is considered that the land could be developed to a density of 30 dwellings per hectare as envisaged at part a) of the policy, which could deliver up to 150 sustainable homes (38 affordable), public open space and Biodiversity Net Gain delivered on site, in line with Policies HOU8, CLC6, CLC8, HEC2 and NAT3. The provision of housing on this site would be consistent with "the Government's objective of significantly boosting the supply of homes" at paragraph 61 of the NPPF. Additional housing beyond the target in Policy OSS1 will provide greater choice and competition, easing affordability concerns in the market. There is also the potential for the inclusion of a proportion of serviced self-built plots in line with Policy HOU6 and the Housing and Planning Act 2016 to meet the needs of those currently on the Council's register and future need.

Where the alignment of Hemsby Road heads east and then south this will provide containment to the development. There is currently the Medical Centre to the west, with existing residential development to the northeast at 25-57 Hemsby Road, new residential development and woodland to the north which limit the landscape impact and make the land less sensitive to development. The land is large enough to maintain existing trees and hedgerows in line with Policies NAT1 and NAT10 and to accommodate substantial landscaping in line with part d) of Policy MAR5 and Policy NAT7, particularly to the south.

The allocation of this additional land would provide more funding through the Community Infrastructure Levy for the upgrading and expansion of the services identified in paragraphs 6.155 to 6.157 in addition to that within Policy OSS4. The development of this additional land would better connect 25-57 Hemsby Road to the rest of the village providing safe pedestrian access in the form of a 2m wide pavement which would be of benefit to these existing residents as well and the residents of the new dwellings. In addition, the development could provide contributions towards the Norfolk Green Infrastructure and Recreational Avoidance Mitigation Strategy.

The allocation of this additional land for open market and a policy compliant level of affordable housing (25%) would contribute to a more balanced and vibrant community and be less likely to result in isolation for those living within the elderly accommodation proposed within the current allocation. In this regard it is noted that Policy HOU4 seeks to "avoid an over concentration of any particular type of housing". Therefore, a broader allocation should be provided to satisfy this policy.

The NPPF is clear at paragraph 73 that "Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly". Therefore, development is more likely to be delivered on sites such as this sooner than larger sites with greater infrastructure requirements.

Suggested amendments to the plan:

We would urge the Council to allocate the additional land adjacent to MAR5 for open market and affordable housing, with open space, landscaping and biodiversity enhancements, all of which could be achieved on site. The allocation of the additional land for this purpose would help provide a more balanced community, whilst limiting the landscape impact and better connecting 25-57 Hemsby Road to the rest of the village. This change would ensure that the plan is consistent with national policy and provides a justified approach to effectively meet the development needs in the Borough.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 222 / Respondent: David Bentley

Date Received: 1/30/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB25

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Does not comply with Duty to Co-operate

Reasons: I am an ecologist. Google Earth shows the site was rough grass in 1999. It has turned to woodland and bramble scrub. It may be locally important for birds, mammals, reptiles, invertebrates, some of which may be protected or Priority Species, each of which the council has a legal biodiversity duty to conserve. NBN Atlas and iRecord have almost no wildlife records. It is not a Priority Habitat (yet), it is not a Local Wildlife Site. The Draft Local Plan does not include any reference to ecology other than a BNG statement made by a planner. The draft local plan in itself fundamentally does not understand that BNG is an additional requirement over and above all the various environmental policies, local and national. It is wrong to move straight to BNG. An ecological survey (there are many charlatans out there) should properly describe all of the species and evaluate them in a Norfolk and National basis. As there has been no survey work the planners cannot assume that the site can be developed. Best Practice and the NPPF requires that sites are properly considered for biodiversity at the production of a plan. Not ignored and not after the plan is adopted. It is clearly important for informal recreation. If it belongs to the LA then the fly tipping is there due to the malaise of the Council. In any case the Council could have taken enforcement action

Suggested Modifications: I am an ecologist. Google Earth shows the site was rough grass in 1999. It has turned to woodland and bramble scrub. It may be locally important for birds, mammals, reptiles, invertebrates, some of which may be protected or Priority Species, each of which the council has a legal biodiversity duty to conserve. NBN Atlas and iRecord have almost no wildlife records. It is not a Priority Habitat (yet), it is not a Local Wildlife Site. The Draft Local Plan does not include any reference to ecology other than a BNG statement made by a planner. The draft local plan in itself fundamentally does not understand that BNG is an additional requirement over and above all the various environmental policies, local and national. It is wrong to move straight to BNG. An ecological survey (there are many charlatans out there) should properly describe all of the species and evaluate them in a Norfolk and National basis. As there has been no survey work the planners cannot assume that the site can be developed. Best Practice and the NPPF requires that sites are properly considered for biodiversity at the production of a plan. Not ignored and not after the plan is adopted. It is clearly important for informal recreation. If it belongs to the LA then the fly tipping is there due to the malaise of the Council. In any case the Council could have taken enforcement action.

Request to be heard?: No

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 223 / Respondent: Anglian Water Services Ltd

Date Received: 1/30/2025 8:51:00 PM

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy OSS3

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Anglian Water supports the policy in terms of development outside the development limits where this comprises the provision of utilities infrastructure. Given the nature of our assets and networks, we often require new infrastructure, or extensions to existing infrastructure (such as WRCs) to be located outside the development limits.

Suggested Modifications:

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 224 / Respondent: Anglian Water Services Ltd

Date Received: 1/30/2025 8:51:00 PM

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy OSS4

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Anglian Water supports the policy requirements particularly regarding the final paragraph which reflects impacts on infrastructure capacity and risks to the environment, the economy or society which cannot be mitigated. We consider that this is an appropriate measure to avoid unacceptable adverse effects on the environment and local communities.

Our five-year plan from 2025 to 2030 (known as AMP8) includes significant investment planned for both water and wastewater infrastructure across our region. We will need high levels of sustained investment much further into the future to ensure our

infrastructure is able to safeguard the environment, be resilient to climate change and cope with changing demands for water and water recycling services and increasing levels of growth.

We would advise developers to seek early pre-planning engagement with Anglian Water to discuss their proposals and ensure they do not present a risk of pollution and/or flooding to our network. In cases where there are constraints to network capacity we may require a sustainable point of connection to our network to mitigate these impacts. This would accord with Policy OSS4 requirements and infrastructure capacity.

A high level summary of the site allocations, both individually and cumulatively, indicate that there may be some localised network reinforcement (including pumping stations) and/or a risk to network capacity and combined storm overflow compliance, that arise from many of the sites. We see this policy as a critical element to ensuring engagement and suitable mitigation is in place, so there is sufficient and robust infrastructure to protect existing communities and the environment.

Suggested Modifications:

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 225 / Respondent: Anglian Water Services Ltd

Date Received: 1/30/2025 8:51:00 PM

Section of the Plan: 5

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CAS1

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Anglian Water suggests paragraph 5.30 is updated to ensure it is factually correct and include relevant data in respect of infrastructure requirements for this strategic site.

Currently the paragraph refers to a rising water main. Our previous reference to a rising main is in fact a pressurised sewer pipe that transfers waste water flows from a pumping station to Caister Water Recycling Centre (WRC). It is therefore important that the pipe and any easements associated with it are taken into account in the design and layout of the site, so it can be accessed for maintenance.

In addition, wastewater flows from this site will need to be conveyed directly to the WRC or a terminal pumping station as there is no capacity in the local network to accommodate flows from this scale of growth.

Suggested Modifications: Revised wording:

A rising main (pressurised sewer) exists on the northern boundary, therefore in accordance with Policy CLC3 it is expected that suitable access is safeguarded for the maintenance of this wastewater infrastructure through appropriate site layouts. Wastewater flows from this site will need to be conveyed directly to the water recycling centre or a terminal pumping station as there is no capacity in the local network to accommodate flows from this scale of growth. Early discussion with Anglian Water is advised.

Request to be heard?: No

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 226 / Respondent: Anglian Water Services Ltd

Date Received: 1/30/2025 8:51:00 PM

Section of the Plan: 12

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HEC3

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Anglian Water has a sewage pumping station within the area identified as Bluebell Woods/Hobland plantation north of Gorleston Beacon Innovation Centre. We would request that our asset is omitted from the local green space designation, as the policy requirements could affect proposals for any future upgrades that may be required to support the effective operation of our critical infrastructure. It is evident from the mapping and aerial photography that the pumping station is clearly shown within an enclosure and access track

Suggested Modifications: Amendment to the Policies Map to omit the area of the sewer pumping station serving Gorleston Beacon Innovation Centre from the local green space identified for Bluebell Woods/Hobland plantation.

Request to be heard?: No

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 227 / Respondent: Anglian Water Services Ltd

Date Received: 1/30/2025 8:51:00 PM

Section of the Plan: 12

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HEC7

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Anglian Water welcomes the supporting text to this policy which explains the odour assessment requirements from developments in proximity to our water recycling centres and sewage pumping stations. We consider this is a helpful explanation to assist applicants that may introduce an 'agent of change', where the risk of unacceptable odour to sensitive receptors should be avoided.

We suggest a minor amendment to reference the Norfolk Minerals and Waste DPD wastewater consultation area (Policy CS16) which extends 400m from our water recycling centres (which is also included in the Norfolk Minerals and Waste Local Plan that is at the later stages of examination). This is referenced in the context of Policy URB22, so it would be consistent with the cross reference with the supporting text of that policy.

Suggested Modifications:

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 228 / Respondent: Anglian Water Services Ltd

Date Received: 1/30/2025 8:51:00 PM

Section of the Plan: 14

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CLC2

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Many of the brownfield urban sites are within Flood Zone 3a and we note that the allocation policies will require site specific Flood Risk Assessments, which will need to take account of the Environment Agency's NaFRA2 products including an updated flood map for planning due in March 2025. The updated NaFRA2 flood mapping will have a bearing on the outcome of the Sequential and Exception Site approach to managing flood risk given that the SFRA Level 1 dates from 2017 and whilst the Local Plan references that a Level 2 SFRA has been undertaken it does not appear to have been published on the evidence base list to support the preferred sites. The approach therefore appears to rely on site specific FRAs being submitted to support future planning applications on these sites and take account of updated flood risk and coastal erosion data, which could impact on deliverability.

In the Sequential Test Report December 2024, eight of the preferred site allocations have been assessed in terms of more vulnerable residential uses given the spatial strategy focus on growth and regeneration of the urban areas. The report also refers to further work being undertaken as part of the Level 2 Strategic Flood Risk Assessment which will also provide information to inform the application of the 'Exception Test'. The Consultation Statement also refers to reviewing the Level 1 SFRA and preparing a level 2 SFRA following comments from the Environment Agency. Anglian Water recognises that the Council refers to the Level 2 SFRA findings in support of this policy, but its absence in the Evidence Base list is unhelpful to inform the application of the Exception Test or to address updated flood risk and coastal erosion data. Whilst sites being located in the urban areas bring sustainability benefits and regeneration opportunities, we question whether these benefits have substantial enough weight when considered against revised climate change allowances, the potential for increased sewer flood risk, and the embodied (capital carbon) and design-life of new buildings and supporting infrastructure. We will aim to confirm the position with the Council in due course, and may make further submissions in support of our partner Risk Management Authorities (the Environment Agency and Lead Local Flood Authority).

A-WINEP:

Effective surface water management is a strategic priority for Anglian Water in AMP8, with growth and flood risk management being strongly aligned with our environmental ambitions and emphasis on overflow spill reduction.

To deliver this sustainably for the environment and our customers, we will be looking to maximise the use of nature-based solutions as part of a toolkit of measures. Sustainable drainage schemes offer a green alternative to grey storage, but their use at scale is still in its infancy. Our water industry national environment programme (WINEP) will promote green solutions as part of Anglian Water's core delivery, but we also seek to go further through our Advanced-WINEP, promoting partnership action to co-fund and deliver solutions for multiple beneficiaries. This approach will allow us to maximise opportunities for partnership action and deliver wider outcomes than could be achieved otherwise.

The Advanced WINEP programme centres around the collaborative development and delivery of nature-based solutions for wider catchment benefits. This includes the installation of sustainable drainage systems (SuDS) and green infrastructure across target catchments that include Caister/Great Yarmouth to remove surface water from Anglian Water's combined sewer system and reduce the number of overflow spills in the catchment. As a large-scale, sustainable water management scheme, it will improve flood resilience and water sustainability, whilst also providing social, environmental, and economic benefits, improving the public realm with the creation of green and blue hubs and corridors, and providing the public with access to nature.

We will continue to work with our regulators to evidence the art of the possible and support policy discussions in this space. It is therefore essential that new developments manage surface water in accordance with the drainage hierarchy and provide betterment wherever possible to help minimise the impact of surface water flooding on existing communities.

Suggested Modifications: Anglian Water would request the publication of the Strategic Flood Risk Assessment Level 2 to be satisfied the necessary up to date evidence has been undertaken for the preferred sites, including the appropriate application of the Exception Test. Whilst we may have overlooked this, it is not evident on the website - only the SFRA Level 1 (2017) and the Sequential Test Report.

Request to be heard?: No

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 229 / Respondent: Anglian Water Services Ltd

Date Received: 1/30/2025 8:51:00 PM

Section of the Plan: 14

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CLC3

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons:

Anglian Water is supportive of the policy, which is consistent with our approach to sustainable and resilient growth and ensures that developers undertake early engagement with us to discuss their proposals and any resulting infrastructure requirements, in accordance with Policy OSS4.

As we have previously identified that a number of the site allocations have underground pipes (water mains, foul sewers and rising mains) and some of these are referenced in the supporting text to these policies, we support the requirement to ensure that suitable access is safeguarded for the maintenance of our underground assets

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 230 / Respondent: Anglian Water Services Ltd

Date Received: 1/30/2025 8:51:00 PM

Section of the Plan: 14

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CLC4

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Anglian Water continues to support this criteria-based approach to renewable energy development. We consider that this provides a flexible approach to enable net zero ambitions to be realised. We have installed a range of renewable and low carbon energy developments at our operational sites across our region to help reach our net zero target by 2030.

Suggested Modifications:

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 231 / Respondent: Anglian Water Services Ltd

Date Received: 1/30/2025 8:51:00 PM

Section of the Plan: 14

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CLC8

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Anglian Water is the statutory water undertaker for a small area of the borough to the north within Happisburgh water resource zone, however, we also recognise that water efficiency measures also reduce the volume of water being treated by our water recycling centres and help to reduce carbon emissions. We support for the ability for planning policy to set future local standards for water efficiency which aligns with our overall approach to demand management in our Water Resources Management Plan 2025-2050 - our plan demonstrates that there are significant challenges across our region in terms of the reduction of water available for use due to abstraction licence caps, environmental destination (achieved by reducing the amount of water we abstract further), ensuring sufficient resources available for 1:500 year drought, climate change, and population growth.

Making best use of existing resources through demand management is therefore an important element of meeting the supply-demand balance, for existing households this will be achieved through the roll out of smart metering and customer engagement, plus quicker identification of customer supply side leakage. New development, however, can provide improved demand management measures to facilitate reductions in demands on potable water resource, including water efficient fixtures and fittings, rainwater harvesting and reuse, and greywater recycling. Future demand in the Water Resources Management Plan has been modelled with per capita consumption/PCC reduction included and so water efficiency measures from developers need to be part of future plans, along with our own demand management options.

This is reinforced by the work we are undertaking with water companies across the East of England, Natural England and the Environment Agency on shared standards for water efficiency in local plans, to support local planning authorities in applying tighter water efficiency standards beyond the higher optional standard of 110 litres per person per day. The Defra Integrated Plan for Water supports the need to improve water efficiency and the Government's Environment Improvement Plan sets ten actions in the Roadmap to Water Efficiency in new developments including consideration of a new standard for new homes in England of 100 litres per person per day (lpppd) where there is a clear local need, such as in areas of serious water stress. Given the proposed national approach to water efficiency, Anglian Water would suggest that this standard is included in the Local Plan as a minimum. This is consistent with the main modifications for Tendring and Colchester Borders Garden Community (supported by Anglian Water and the lead developer) and the main modifications for the King's Lynn and West Norfolk Local Plan in support of the West Winch Strategic Growth Area. We would encourage strategic developments to go further and include integrated water management measures such as rainwater harvesting and reuse which aligns with Design Code CC4. Implementing the 110 lpppd standard is extremely low in relation to the overall cost of development, we therefore consider that more ambitious standards, even if only to the Environmental Improvement Plan stated level of 100 lpppd would be achievable and affordable through a fittings-based approach.

The Shared Standards will be underpinned by a supporting evidence base, and work on developing viability options for rainwater harvesting and reuse and greywater reuse - particularly at community scale to help inform local planning authority policy making. There are already significant water scarcity challenges in Greater Cambridge (emerging Local Plan proposes water efficiency measures of 80 litres per person per day) and there is a risk that similar challenges will be faced elsewhere in East Anglia if all sectors do not work together now to be more water efficient and save water.

Anglian Water can no longer guarantee to supply non-domestic water requirements for intensive/high water consumptive uses such as manufacturing/ food processing and production. Our regulatory position means we are unable to supply new non-domestic demands if this jeopardises domestic supplies for existing and new residential customers and businesses. Therefore, where new and unplanned non-domestic water requests are received, which exceed 20,000 litres per day, Anglian Water will need to decline the request for more water in order to protect existing supplies and the environment. Our updated Non Domestic Water Request Policy can be found here: https://www.anglianwater.co.uk/siteassets/developers/new-content/pre-dev/aws-non-domestic-demand-policy-sm-v2.pdf

Future household and non-household developments will need to rise to the challenge of saving and delivering water for their schemes, driving forward innovative solutions, and exploring the full range of water efficiency, re-use, and offsetting options to ensure their developments are sustainable and significantly reduce reliance on potable water demand.

Anglian Water recommends that the new Local Plan includes policies that require new employment growth to be water efficient or water neutral to ensure that economic growth can be delivered sustainably. We would wish to see a more ambitious approach to water efficiency in new non-household development to aspire to achieving the full credits in Wat01 BREEAM.

Suggested Modifications: Proposed modification:

All new homes must include water saving measures and, as a minimum, meet the Government's Environment Improvement Plan (Water Efficiency Roadmap) standard of 100 litres per person per day, unless superseded by tighter water efficiency standards through a revised higher optional standard in Building Regulations Part G2.

Proposals should submit a water efficiency calculator report to demonstrate compliance, and developers are encouraged to demonstrate how they can go further utilising integrated water management and a fittings-based approach to minimise potable water use (see Design Code CC4).

Non-residential development will meet the BREEAM "Very Good" water efficiency standard, or equivalent successor. Projects are expected to aspire to achieve the full credits for category Wat 01 of BREEAM unless demonstrated impracticable.

Request to be heard?: No

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 232 / Respondent: Pamela GrapesHarris

Date Received: 1/30/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB25

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: We do need more homes for the next generation of young sters living locally But not at the expense of wildlife also squeezed in housing development on Green Fields within our town itself. "Less is More"....

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 233 / Respondent: Jane Ray

Date Received: 1/31/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB25

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Does not comply with Duty to Co-operate

Reasons: Building 70 houses on site URB25 would have a huge and detrimental impact on the natural woodland area. It has formed a long standing habitat for various wildlife, muntjac, foxes, rabbits, and many more. Also here is a biodiversity culture of mother nature and to concrete over this would be devastating. The Acle Straight has never been permitted due to protected wildlife. Who know what might be in this area.

Alongside the wildlife is an extensive range of fruit trees, apple trees, cherry trees to name but a few.

This development should not be allowed to go ahead at the expense of all that is mother nature. It would be killing animals and trees.

Suggested Modifications:

Building 70 houses on site URB25 would have a huge and detrimental impact on the natural woodland area. It has formed a long standing habitat for various wildlife, muntjac, foxes, rabbits, and many more. Also here is a biodiversity culture of mother nature and to concrete over this would be devastating. The Acle Straight has never been permitted due to protected wildlife. Who know what might be in this area.

Alongside the wildlife is an extensive range of fruit trees, apple trees, cherry trees to name but a few.

This development should not be allowed to go ahead at the expense of all that is mother nature. It would be killing animals and trees.

Request to be heard?: No

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 234 / Respondent: Mealnie Parker

Date Received: 1/31/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB20 4.197-4.201

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Does not comply with Duty to Co-operate

Reasons: This area of land has had previous investment, building walk ways and fence to make it a space for the community to enjoy. There is no other easily accessible, wooded area and spaces like this are essential for the physical and mental wellbeing of all who use it. Workers who walk in their break to family's and pets. This space is too valuable to the community too be built on when other areas are sitting vacant and add nothing to the town.

Suggested Modifications: Do not build here!!! Save our woodland.

Request to be heard?: No

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 235 / Respondent: Phill Martin

Date Received: 1/30/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB25

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound

Reasons: PLEASE make the woods a peaceful area. There are foxes, muntjac and many birds in that wood.

Please please don't build houses.theres nowhere to park in the Church Road/Church Lane/Recreation Roads as it is, and the congestion will be awful. Make some paths, add benches, plant it out. Bit don't build on it!

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 236 / Respondent: East Suffolk Council Adam Nicholls

Date Received: 1/31/2025

Section of the Plan: 1

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Introduction and Duty to Cooperate

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: East Suffolk Council fully supports the ongoing work with Great Yarmouth Borough Council in relation to addressing cross-boundary planning matters and welcomes reference at para 1.14 to the regular planning liaison meetings that are attended by both Great Yarmouth Borough Council and East Suffolk Council. The Council notes (at para 1.16) confirmation that the Local Plan sets out policies to meet all the needs for housing and economic development within the Great Yarmouth Borough and that there is no need for neighbouring areas to meet any outstanding need the Borough. The two councils agreed (in January 2025) a Statement of Common Ground about various planning matters and for the avoidance of any doubt, the Council has no Duty to Co-operate concerns about the Local Plan.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP236-250 - East Suffolk Council (PDF, 191 KB)(opens new window)

Rep ID: 237 / Respondent: East Suffolk Council Adam Nicholls

Date Received: 1/31/2025

Section of the Plan: 2

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Vision and Objectives

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: East Suffolk Council supports the Vision and Objectives set out in the draft Local Plan.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP236-250 - East Suffolk Council (PDF, 191 KB)(opens new window)

Rep ID: 238 / Respondent: East Suffolk Council Adam Nicholls

Date Received: 1/31/2025

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy OSS1

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: The Council notes that housing requirement for the period 2024-2041 is 6,460 and that the Local Plan makes provision for approximately 6,640 homes over that period (excluding 'windfall' sites), and that the sensible windfall allowance would take the uplift to 15% above the housing requirement. This is supported as a pragmatic approach.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP236-250 - East Suffolk Council (PDF, 191 KB)(opens new window)

Rep ID: 239 / Respondent: East Suffolk Council Adam Nicholls

Date Received: 1/31/2025

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy OSS3

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: The Council supports the Development Limits policy, noting particularly that one of its aims is (paragraph 3.18) is to help the unplanned coalescence of settlements. The Council's particular concern is to ensure that the villages of Hopton and (over the border in East Suffolk) Corton to not merge or appear to merge (this is covered also in representations on policies HOP1 and HOP2 below).

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP236-250 - East Suffolk Council (PDF, 191 KB)(opens new window)

Rep ID: 240 / Respondent: East Suffolk Council Adam Nicholls

Date Received: 1/31/2025

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy OSS4

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: The Council welcomes the strategic transport improvements highlighted in the policy - the improvements to the A47 and A143 would also be of some benefit to East Suffolk. The reference to improved cycle and pedestrian links between Gorleston and Lowestoft is particularly supported.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP236-250 - East Suffolk Council (PDF, 191 KB)(opens new window)

Rep ID: 241 / Respondent: East Suffolk Council Adam Nicholls

Date Received: 1/31/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB17

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: The Council support the proposed redevelopment of the James Paget University Hospital and the delivery of improved healthcare provision. As acknowledged in the supporting text, the hospital plays in important role in communities beyond Great Yarmouth Borough, in particular in the northern part of East Suffolk. Specific reference to improved pedestrian and cycle links to and through the site is supported.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP236-250 - East Suffolk Council (PDF, 191 KB)(opens new window)

Rep ID: 242 / Respondent: East Suffolk Council Adam Nicholls

Date Received: 1/31/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB20

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: The Council support the identification of land for energy-based industries and this aligns with the wider ambitions for the region.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP236-250 - East Suffolk Council (PDF, 191 KB)(opens new window)

Rep ID: 243 / Respondent: East Suffolk Council Adam Nicholls

Date Received: 1/31/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB21

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: The Council support the provisions within this allocation, in particular the reference made in the policy and the supporting text to a cycleway that supports the aim of 'Route 7' Gorleston to Lowestoft. This approach aligns with equivalent recommendations in the East Suffolk Cycling and Walking Strategy.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP236-250 - East Suffolk Council (PDF, 191 KB)(opens new window)

Rep ID: 244 / Respondent: East Suffolk Council Adam Nicholls

Date Received: 1/31/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HOP1

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: -

Suggested Modifications: As raised elsewhere too, the Council reiterates the need to maintain an effective strategic gap between Hopton and Corton and supports the requirements of criteria f) of the policy and paragraph 6.94 (for a Landscape Visual Impact Assessment to inform the layout and landscaping of the development). However, it is important that this requirement is strengthened to ensure that the significant landscape belts to the south and south-west edges of the site are delivered early in the life of the development, so that it can mature before the dwellings closer to the edge are in place. If this does not happen, it could risk a short-medium term perception of coalescence. For the same reason, the long-term protection/management of the structural landscaping is essential. The potential improvements to Longfulans Lane which could be delivered through this site allocation (in conjunction with HOP2) and support the aspiration to deliver a shared-use cycle path along the south side of Longfulans Lane, helping to facilitate a future active travel route between Gorleston and Lowestoft, are acknowledged. In particular, the Council welcomes the specific reference to proposed active travel corridors in East Suffolk in the supporting text. This joined-up approach to active travel provision is supported by East Suffolk Council.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP236-250 - East Suffolk Council (PDF, 191 KB)(opens new window)

Rep ID: 245 / Respondent: East Suffolk Council Adam Nicholls

Date Received: 1/31/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HOP2

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: -

Suggested Modifications: The Council recognises that this allocation is level with existing development (to the west) and is set back slightly from the Potters Resort (to the east). It is recognised in paragraph 6.106 that a lower-density scheme is appropriate for the site, in part due to the Strategic Gap between Corton and Hopton amd the lower density character of the area. But paragraph 6.109 states that, due to the need to widen Longfulans Lane, the loss of some trees and hedgerows on the site will be necessary and due to the small site size, it won't be possible to provide compensatory planting within the site.

Whilst the potential impacts on coalescence will clearly be lower than for HOP1, and the widening of Longfulans Lane is needed, a similar approach to HOP1 - with a reduced scale/significance of development on the southern edge - would be beneficial. This does not necessarily need to be lower density, but could be bungalows, or the dwellings set back a little from Longfulans Lane.

The cycling and walking connectivity improvements that this policy sets out to deliver, and the potential for improvements to Longfulans Lane which could be delivered in conjunction with allocation HOP1, are both welcomed.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP236-250 - East Suffolk Council (PDF, 191 KB)(opens new window)

Rep ID: 246 / Respondent: East Suffolk Council Adam Nicholls

Date Received: 1/31/2025

Section of the Plan: 13

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy SUT1

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: The Council supports the requirements of this policy and, in particular the reference to the safeguarding of the strategic cycling and pedestrian route between Gorleston and Lowestoft.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP236-250 - East Suffolk Council (PDF, 191 KB)(opens new window)

Rep ID: 247 / Respondent: East Suffolk Council Adam Nicholls

Date Received: 1/31/2025

Section of the Plan: 14

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CLC1

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: The Council strongly supports this policy which, as stated in the supporting text, aligns with that taken in East Suffolk, in accordance with the Statement of Common Ground on Coastal Zone Planning between the Borough Council of King's Lynn & West Norfolk, North Norfolk District Council, Great Yarmouth Borough Council, East Suffolk Council and the Broads Authority.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP236-250 - East Suffolk Council (PDF, 191 KB)(opens new window)

Rep ID: 248 / Respondent: East Suffolk Council Adam Nicholls

Date Received: 1/31/2025

Section of the Plan: 14

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CLC5

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: The Council support the approach in this policy and the specific reference to the joint Coastal Adaptation Supplementary Planning Document. The policy could however benefit from further clarification around the marketing requirements for rollback plots. Part of the policy requires a 6-month marketing for sites adjacent to Hemsby and Scratby before they could be considered for non-rollback uses. This seems very short given the uncertainties and complexities in securing rollback plots- 12-18 months (at least) may be more appropriate.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP236-250 - East Suffolk Council (PDF, 191 KB)(opens new window)

Rep ID: 249 / Respondent: East Suffolk Council Adam Nicholls

Date Received: 1/31/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT4

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: The Council supports the approach to the protection of habitats and species as outlined in this policy, including the Norfolk Green Infrastructure and Recreational Avoidance and Mitigation Strategy (GIRAMS). This aligns with the approach set out in the Suffolk Recreational disturbance Avoidance and Mitigation Strategy (RAMS), which applies across East Suffolk.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP236-250 - East Suffolk Council (PDF, 191 KB)(opens new window)

Rep ID: 250 / Respondent: East Suffolk Council Adam Nicholls

Date Received: 1/31/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT8

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: As stated in the response to various other policies, the Council is supportive of this policy, in particular the commitment to maintaining the separation and avoiding coalescence between Hopton-on-Sea and Corton.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP236-250 - East Suffolk Council (PDF, 191 KB)(opens new window)

Rep ID: 251 / Respondent: Brown & Co on behalf of ESCO Development Ltd & Flagship Housing Developments R

Date Received: 1/31/2025

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy OSS1

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: from 12 March 2025 other than where one or more of five criteria apply. The assessment of these criteria is:

a) The housing requirement does not meet at least 80% of the local housing need - we calculate that this as 72%,

b) The plan has not been submitted for examination,

c) There are no other preceding local plans that have been adopted since 12 March 2020,

d) There is not an operative Spatial Development Strategy in place, and

e) The plan does not only deal with minerals and/or waste matters.

Therefore, as none of the above criteria are met, the policies in the revised version of the NPPF do apply. This includes the requirement to update the housing supply for the Borough to reflect the increased housing requirements. This fails part (d) of the criteria of soundness as the Plan would not be consistent with national policy.

Suggested Modifications: The Plan should take account of the latest housing supply requirements as set out in the current NPPF, which will require that the proposed housing allocations are re-considered to increase the number of dwellings provided and new deliverable sites should be identified including site ref: S37 in Ormesby St Margaret, for 111 dwellings.

Request to be heard?: Yes

Reason for Request to be heard:To be able to present our evidence to the inspector, providing any additional information as required and to respond directly to any questions that the inspector may have.

Attachments: N/A

Rep ID: 252 / Respondent: Brown & Co on behalf of ESCO Development Ltd & Flagship Housing Developments R

Date Received: 1/31/2025

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy OSS1

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: The Plan proposes a substantial re-allocation of housing sites from the current Local Plan. 862 dwellings or 47.8% of the total houses allocated from the current Local Plan have been 'rolled over' to the emerging Plan. The largest of these is Policy URB21, which is allocated for 600 homes and was previously allocated under Policy GN1 for 500 homes. There has not been any planning application submitted to develop this site. To re-allocate such a high proportion of existing allocations, where no planning application has been submitted fails part (c) of the criteria of soundness as the re-allocation and the increase in the number of dwellings to be allocated on the sites that have not been submitted for planning permission mean that the Plan would not be effective in delivering the housing supply required.

Suggested Modifications: There should be less reliance on sites that have been allocated for housing previously but have not received a planning application to develop, and some of these 'rolled-over' sites should not be re-allocated and not have the number of houses to be allocated increased. Also, a greater number of new deliverable and developable sites that score highly in the HELAA assessment should be allocated for housing including site ref: S37 for 111 dwellings, as the housing allocation in Ormesby St Margaret.

Request to be heard?: Yes

Attachments: N/A

Rep ID: 253 / Respondent: Brown & Co on behalf of ESCO Development Ltd & Flagship Housing Developments R

Date Received: 1/31/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy ORM3

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: A full planning application was submitted for a site on Yarmouth Road, Ormesby St Margaret for 71 dwellings in 2020, under application ref: 06/20/0423/F. This was refused in November 2020 on grounds that it is an unsustainable location for this scale of development, notwithstanding the tilted balance. Also, the size and depth of the proposal creates an intrusion into open countryside where rising land exacerbates the impact and will further the coalescence of Ormesby with Caister. The site is also on Grade 1 agricultural land. Despite these fundamental reasons for refusal this site is one of the Council's proposed housing allocations - Policy ORM3 for 125 dwellings, for more houses than previously refused. To allocate this site for housing fails part (d) of the criteria of soundness as the location and nature of the site mean that the allocation of this site would be unsustainable and would not be consistent with national policy or the Council's Policy NAT8 to avoid the coalescence of settlements, with Caister and Ormesby St Margaret specifically identified.

In addition, this site has two separate HELAA references, the first ref: S34/36 for 69 dwellings had a low suitability score, but confusingly the more recent ref: S138 for 125 dwellings for an enlarged site, had a favourable suitability score. There is no reference to the previous refusal in either assessment. This fails part (b) of the criteria of soundness as the changes to the consideration of this site during the plan preparation process without proper consideration of the reasons for refusal of the previous planning application are not justified as demonstrating an appropriate strategy which has taken into account the reasonable alternatives and is not based on proportionate evidence

Suggested Modifications: Remove the housing allocation proposed by Policy ORM3 for the reasons given, as this is an unsustainable location for a development of 125 dwellings in a location with an adverse impact on the landscape and results in a further coalescence of Ormesby St Maragaret and

Caister on Sea. This housing allocation should be replaced by a housing allocation for site ref: S37 for 111 dwellings as the housing allocation in Ormesby St Margaret.

Request to be heard?: Yes

Attachments: N/A

Rep ID: 254 / Respondent: Brown & Co on behalf of ESCO Development Ltd & Flagship Housing Developments R

Date Received: 1/31/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy ORM1

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: A site on Cromer Road, Ormesby St Margaret has been re-allocated for 200 dwellings (under ORM1) but it is known that the archaeological remains of St Peters Church are present on site. It is within proximity of two grade II listed buildings and is within an area identified with cropmarks from the Norfolk Historic Environment records, believed to be from the church and possible burials. The policy wording for this site sets out that approximately 1.96 hectares of the site should be retained as open space to avoid the remains of St Peters Church. The total site area is 8.56 hectares so at least 22% of it can't be developed for housing, this could increase once a full archaeological assessment has been undertaken to include the former churchyard. This site is allocated for 190 dwellings under the current Local Plan, but no planning application has been submitted to develop it. We are concerned that the development of this site for the proposed number of dwellings is highly unlikely to be deliverable over the plan period due to the heritage assets and stated limitations to development. This fails part (c) of the criteria of soundness as the archaeological constraints on site and the increase in the number of dwellings to be allocated mean that the allocation of this site and the Plan as a whole would not be effective in delivering the housing supply required.

Suggested Modifications: Remove the proposed housing allocation ORM1 in Ormesby St Margaret for the reasons given and replace it with a housing allocation for site ref: S37 for 111 dwellings as the housing allocation in Ormesby St Margaret

Request to be heard?: Yes

Attachments: N/A

Rep ID: 255 / Respondent: Brown & Co on behalf of ESCO Development Ltd & Flagship Housing Developments R

Date Received: 1/31/2025

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy OSS1

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: The details of proposed site ref: S37 has significantly changed since the Reg. 18 submission in May 2024 and the publication of the Council's Pre-submission Document. Planning application ref: 06/23/0504/F for 55 dwellings at land north of Barton Way, Ormesby St Margaret, (in part Policy ORM2) immediately to the south of the proposed site, has a resolution for full approval from the Borough Council's Development Management Committee on 11 December 2024. The s.106 agreement is being negotiated, and it is anticipated that full planning permission will be issued in March 2025. Site S37 is more closely related to the built-up area of the village than the sites that have been allocated, and is in close proximity to the village schools, services and facilities. The stated reasons for not allocating this site for 111 dwellings will be overcome as a result of the planning permission. This site is in single ownership and is developable and deliverable. To not allocate site S37 for housing fails part (b) of the criteria of soundness as it is not justified as demonstrating an appropriate strategy which has taken into account the reasonable alternatives and is based on proportionate evidence.

Suggested Modifications: Include site ref: S37 for 111 dwellings as the housing allocation in Ormesby St Margaret.

Request to be heard?: Yes

Attachments: N/A

Rep ID: 256 / Respondent: Brown & Co on behalf of ESCO Development Ltd & Flagship Housing Developments R

Date Received: 1/31/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT3

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Policy NAT3 requires that 'all major development proposals must deliver at least 20% measurable biodiversity net gain attributable to the development.' The exception to this is brownfield sites, and areas within the Development Limits of Great Yarmouth, Gorleston-on-Sea, Bradwell and Caister-on-Sea, where the requirement will be 10%. A 20% requirement exceeds the 10% mandatory requirement which was set by the Environment Act 2021. We are seriously concerned that this increased requirement will adversely affect the ability of the allocated sites to deliver the number of houses required, based on the need to provide BNG within the site and the consequences for the viability of the development.

The Council's Topic Paper on this issue includes an assessment of viability and refers in paragraph 1.29 to Natural England's biodiversity net gain study which references a report from Vivid Economics dated June 2018, and references at paragraph 1.31 a report from Savills dated May 2018. This research was compiled before COVID and does not take into consideration the increase in build costs due to several global events, including the increase in utility prices which have forced up the costs of materials and labour to high levels of inflation. Nor does it provide sufficient regional separation in values, as house prices and land value differ substantially across the country. From the information provided in the Topic Paper about the other Councils that have increased their BNG requirement to 20%, the average house price in Great Yarmouth is significantly the lowest of those listed.

This brings into question whether the viability assessment considered through this Topic Paper provides an accurate and reliable baseline of the situation specifically across the Borough, and consequently the additional planting and provision of 20% BNG on-site will inevitably reduce the area within the allocations that is available for the houses to be built upon, raising the issue whether the proposed allocations will successfully provide enough housing to meet the identified need.

Suggested Modifications: Policy NAT3 should removed from the Plan, as the 10% BNG requirements is a mandatory requirement which is set by the Environment Act 2021.

Request to be heard?: Yes

Attachments: N/A

Rep ID: 257 / Respondent: Jamie Robertson

Date Received: 1/31/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB25

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound

Reasons: It's come to my attention there is planning permission for the woodland between meadow park and gorleston recreation ground. It is not a good idea to build on this land, It contains a Habitat of Animals from Foxes for which there are many, I see them every day I walk my dog in the early mornings. There are also many other species inside the woodlands. Taking this away would mean they have no were to go. Creating a problem on the streets distressing the animals and resulting in major upheaval. Also how would builders plan to build on there without effecting the surrounding neighbourhood? So please accept this as an official letter of objection for the councils idea to build on this land. I'm all for new houses but I do believe on this occasions this area needs to be left alone.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 258 / Respondent: Jane Jordan

Date Received: 1/31/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB21

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound

Reasons: Regarding the above proposed development I am writing to register my objections. The access on to Links road would be very detrimental to South Gorleston as an up & coming holiday destination causing deadlock especially in the summertime . The massive increase in traffic from six hundred houses , care home & commercial premises would cause carnage with all the traffic movements & all the infrastructure, doctors, dentist, hospital etc that a development of the proposed size would need. We at present have found that the links road roundabout has been very problematic especially trying to cross to the A143 from Links Road as there is only room for two vehicles to wait at traffic lights or it would obstruct the through flow of the A47. Our fears of traffic backing up to the seafront & causing mayhem to our prestige & very enviable best beach category which has drawn so many more visitors to south Gorleston.

The other routes to access the A47 would cause carnage through the Cliff Park estate plus we have a hospital very close which would cause longer response times. We are also concerned about the height of the ground level behind us in the Fairway & feel it needs to be reduced in height as it would block light out on the boundary lines of the Fairway & Warren lane . Bungalows would be more sympathetic in those area's. I therefore strongly object to this proposed development for all the above reasons feeling it is the wrong area for a development unless access can go via slip roads directly from the A47 to enable the traffic to flow more freely.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 259 / Respondent: Karen Mowle

Date Received: 1/31/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB25

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound

Reasons: I have lived on East Anglian way for 17 years. I see on a daily basis how busy the road is with school traffic, and this is why I strongly apposed the planning for more houses back in 2018. As you are fully aware, the plans were stopped for safety reasons. As far as I am aware, nothing has changed. The school is still open and the road is as busy as ever, as is the entry and exit point on Church Road. The green area we have around East Anglian Way is so vital for wildlife, dog walkers and the publics general well-being. Adding more housing onto our road will destroy this important green space and increase the number of vehicles entering and leaving the road, making it more dangerous for the residents and the young school children. I understand that more homes need to be built, but I fear a lack of common sense amongst developers and the council in certain areas, will cause serious issues which will be irreversible. Please can you explain to me how this is even going to the planning stage after being refused back in 2019, as I am truly baffled.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 260 / Respondent: Michael Powles

Date Received: 1/31/2025

Section of the Plan: 0

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Transport Study

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound

Reasons: Thank you for your various emails concerning the local plan and associated documents. Since I shall not be able to participate in the webinar on 6 January 2025, I am grateful for the opportunity to make my representations via this email. My comments relate to the critical infrastructure in the northern parishes , namely Caister and all parishes to the north which rely on transit through Caister for access to and from the rest of the borough, including the hospital, municipal offices, major shops and the market and all entertainment facilities.

As you will know only one road connects these parishes to the rest of the borough and town of Great Yarmouth. That road is the A149 between the GREYHOUND STADIUM and the junction with FREMANTLE ROAD. When this road is blocked the only other access to the town is via Filby and the hump-backed bridge at Acle in the neighbouring jurisdiction. This route represents a detour of some 20 miles. It emerges onto the single carriageway Acle straight which is frequently at a traffic standstill anyway, especially in summer. This is hardly surprising as the road has barely changed since it was opened in 1831. The Acle Straight (A47) is often closed which means the traffic is diverted the other way via Caister-on -Sea.

A recent Norfolk Police report named the roundabouts at Caister as the most sensitive and critical section of road in Norfolk . It is a pinch point or bottle neck where the A149, A1064 and the B1159 coast road (which connects most of the northern parishes to the rest of the borough) must all filter through. Great Yarmouth, with its hinterland, is surrounded by water and marshes. Viz. three major rivers, the Broads, including Breydon and, of course, the sea. A perusal of the map shows that there is nowhere else to build a road except across marshes and crossing rivers at enormous and disproportionate cost. Yet numerous developer-led housing developments have been permitted in the northern parishes in recent years including one huge development right on top of the sensitive roundabouts at Caister. Nothing has been done to ease the traffic flow with new roads. probably for the reasons set out above. Great Yarmouth is still not connected to the rest of the country by uninterrupted dual carriageway roads.

Nothing has been done to provide other services such as GPs, dentists, sewers, water supplies etc to cope with all the extra population. Experience suggests that most of the new houses built in recent years have been purchased by people, mostly elderly, from outside the county. Few have been affordable to local people. This is an inevitable consequence of developer-led schemes where profit is the sole motivator.

It is important that developers should not be able to bully their way into getting what they want by paying lip service to the current rules and promising to provide services and facilities that either fail to materialise or are provided de minimis. It is not enough to join developments to the nearest country lane when it creates enormous traffic jams at the first junction or beyond. It is frustrating to see how quickly housing developments proceed to fruition while other necessary infrastructural developments take for ever to materialise. A good example is the dualling of the A47 between Burlingham and Blofield, which almost everybody wants but is repeatedly being delayed, compared to the new developer-led housing project on the Caister roundabouts that nobody wants but is galloping ahead.

Finally, I would like to make the point that large numbers of affordable starter homes could be released onto the market if holiday lets were returned to residential use as they were originally intended to be. It is very frustrating to see people who do not vote or pay community charges in the borough making large sums of money to be spent outside the borough by buying up residential property for holiday lets. I fear for our democratic heritance if this building frenzy in the northern parishes continues. We can certainly look forward to traffic chaos.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 261 / Respondent: Rob Haslam

Date Received: 1/31/2025

Section of the Plan: 14

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:General

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: The following paper sets out the framework, need and opportunity for effective, economic and sustainable energies to form the 'heart' of local development and further provide support and enrichment to the Great Yarmouth Borough Council aims and objectives in their Local Plan.

1. What is a Sustainable Home?

A sustainable home is designed to minimise environmental impact while providing a comfortable living space. This includes energy-efficient systems, sustainable materials, and designs that reduce waste and promote renewable energy use.

To be considered a truly sustainable property, a combination of technologies and practices are essential. Here are some key areas:

1. Energy Efficiency:

Renewable Energy Sources:

• Geothermal Systems: Utilize the stable temperatures of the earth for heating and cooling.

• Solar Panels: Capture solar energy to generate electricity, reducing reliance on the grid.

• Wind Turbines (if applicable): Utilize wind power for electricity generation.

• Energy-Efficient Appliances:

o High-efficiency heating and cooling systems (heat pumps, geothermal systems).

o Energy-Star rated appliances (refrigerators, washing machines, dryers).

o LED lighting throughout the property.

• Smart Thermostats:

o Program thermostats to adjust temperatures automatically, optimizing energy use.

o Utilise smart home technology for remote control and monitoring.

2. Water Conservation:

Low-Flow Fixtures:

• Install low-flow toilets, showerheads, and faucets to reduce water consumption.

• Rainwater Harvesting Systems:

• Collect rainwater for irrigation, toilet flushing, or other non-potable uses.

• Greywater Systems:

• Recycle greywater (from sinks, showers, washing machines) for irrigation or other non-potable uses.

3. Sustainable Building Materials:

Locally Sourced Materials:

• Utilise locally sourced and sustainably harvested building materials to reduce transportation emissions.

• Recycled and Reclaimed Materials:

• Incorporate recycled and reclaimed materials whenever possible.

• Low-VOC Paints and Finishes:

• Use low-volatile organic compound (VOC) paints and finishes to improve indoor air quality.

4. Smart Home Technology:

Smart Home Hubs:

• Integrate various smart home devices (lighting, thermostats, security systems) into a single system for centralised control.

• Smart Meters:

o Monitor energy consumption in real-time, providing valuable data for optimizing energy use.

o Home Energy Management Systems (HEMS):

o Analyse energy usage patterns & provide recommendations for reducing energy consumption.

5. Waste Reduction and Management:

Composting:

• Compost food scraps and yard waste to reduce waste and create nutrient-rich soil.

• Recycling Programs:

• Implement comprehensive recycling programs for all residents.

• Waste Reduction Strategies:

o Encourage residents to reduce waste through measures such as food waste prevention and product reuse.

6. Indoor Air Quality:

High-Efficiency Air Filtration Systems:

• Install high-efficiency particulate air (HEPA) filters to improve indoor air quality.

• Proper Ventilation:

o Ensure adequate ventilation throughout the property to remove pollutants and maintain healthy air circulation.

• Low-VOC Paints and Finishes:

o Use low-VOC paints and finishes to minimize indoor air pollution.

7. Green Roofs and Landscaping:

Green Roofs:

• Install green roofs to improve insulation, reduce stormwater runoff, and provide habitat for wildlife.

• Native Landscaping:

• Utilise native plants in landscaping to reduce water consumption and promote biodiversity.

8. Transportation Considerations:

Proximity to Public Transportation:

• Locate the property near public transportation options to reduce reliance on private vehicles.

• Bicycle and Pedestrian Infrastructure:

• Provide safe and convenient bicycle and pedestrian infrastructure to encourage alternative modes of transportation.

By incorporating these technologies and practices, property owners and developers can create truly sustainable properties that minimize their environmental impact and enhance the quality of life for residents.

Geothermal heat network

A geothermal heat network could significantly support a sustainable development in several ways:

Reduced Carbon Emissions: Geothermal energy is a renewable resource that harnesses the Earth's natural heat. By utilising a geothermal heat network, the development can significantly reduce its reliance on fossil fuels for heating and cooling, leading to substantial decreases in greenhouse gas emissions.

Enhanced Energy Efficiency: Geothermal heat pumps are highly efficient, often achieving higher coefficients of performance (COP) than traditional heating and cooling systems.

Improved Air Quality: By reducing the reliance on fossil fuels, geothermal heat networks contribute to cleaner air quality by minimizing the release of pollutants such as nitrogen oxides, sulphur dioxide, and particulate matter.

Increased Sustainability: Geothermal energy is a sustainable and environmentally friendly energy source. Geothermal heat networks have a minimal environmental impact compared to traditional energy sources, making them a crucial component of sustainable development initiatives.

Economic Benefits: Geothermal heat networks can create local jobs in the installation, maintenance, and operation of the system. Additionally, the reduced energy costs for residents and businesses can stimulate economic activity within the development.

Community Resilience: A geothermal heat network can provide a reliable and resilient source of heating and cooling, even during extreme weather events. This can enhance the overall resilience of the development and improve the quality of life for its resident

Overall, a geothermal heat network can be a powerful tool in creating a sustainable and environmentally friendly development. By harnessing the Earth's natural heat, these networks can reduce carbon emissions, improve energy efficiency, and enhance the overall sustainability of the development. This means they can provide more heat or cooling energy for the same amount of electricity input, resulting in lower energy bills for residents and businesses.

2. Understanding the NCC Corporate Plan

A sustainable affordable housing developer can work with Norfolk County Council and North Norfolk District Council's Corporate Plan by aligning their projects with the council's priorities and demonstrating how their developments contribute to the broader goals outlined in the plan.

Thorough Review: Carefully review the North Norfolk District Council's Corporate Plan 2023 to 2027, paying close attention to the five key priorities:

Greener Future: Focus on sustainable building practices, energy efficiency, and renewable energy integration.

Developing Communities: Emphasise community engagement, social value creation, and addressing local housing needs.

Tackling Housing Challenges: Highlight how the development addresses affordability, accessibility, and the diverse housing needs of the community.

Supporting Businesses and Economic Development: Demonstrate how the development can stimulate local economic activity and create jobs.

Financial Stability and Accountability: Ensure the development is financially viable and meets relevant regulations.

3. Aligning with Council Priorities

• Sustainability: Prioritise sustainable building materials, energy-efficient designs, and renewable energy sources to contribute to the "Greener Future" priority.

• Community Focus: Engage with residents, businesses, and community groups throughout the development process to ensure the development aligns with community needs and aspirations.

• Affordability: Offer a range of affordable housing options, including social housing, affordable rent, and shared ownership schemes, to address the "Tackling Housing Challenges" priority.

• Economic Impact: Explore opportunities to create local jobs, support local businesses, and contribute to the local economy.

• Transparency and Accountability: Be transparent about the development process, engage with the council and community, and ensure the development meets all relevant regulations and standards.

4. Building Relationships:

• Early Engagement: Initiate early discussions with the council to build relationships and seek guidance on how to align the development with the Corporate Plan.

• Collaboration: Collaborate with the council and other stakeholders to identify opportunities for partnership and leverage available resources.

• Communication: Maintain open and transparent communication with the council and community throughout the development process.

• Demonstrating Value:

• Quantifiable Outcomes: Track and report on the social, economic, and environmental benefits of the development, demonstrating how it contributes to the council's priorities.

• Innovation: Explore innovative approaches to affordable housing development, such as modular construction, co-housing models, or community land trusts.

• Long-Term Sustainability: Ensure the development is designed and managed for long-term sustainability, considering factors such as energy efficiency, water conservation, and waste management.

By aligning their projects with the North Norfolk District Council's Corporate Plan, sustainable affordable housing developers can not only create high-quality, affordable homes but also contribute to the broader goals of the council and the community.

5. Economics

Investing in sustainable homes can lead to significant economic benefits. Lower utility bills due to energy efficiency, reduced maintenance costs, and potential subsidies for green building practices can enhance affordability for low-income families.

• Initial Costs: Sustainable homes often have higher upfront costs due to the use of eco-friendly materials, advanced technology, and energy-efficient systems. However, these costs can be mitigated through careful planning and use of innovative construction techniques such as modular building.

• Long-Term Savings: While the initial investment may be higher, sustainable homes typically lead to lower operational costs. Energy-efficient designs can result in significant savings on utility bills, with many homes seeing reductions of 30% or more in energy costs. Additionally, sustainable features can lower maintenance costs over time.

• Economic Incentives: The UK government and local councils offer various incentives to promote sustainable building practices. These can include grants, tax incentives, and rebates for using renewable energy sources or for energy-efficient upgrades. In Norfolk, specific programs may be available to home builders and buyers to encourage sustainable practices.

• Property Value Appreciation: Homes built with sustainable features often have higher resale values. As demand for environmentally friendly living increases, properties that offer energy efficiency and reduced environmental impact become more attractive to buyers.

• Job Creation: Investing in sustainable housing can stimulate local economies by creating jobs in construction, renewable energy installation, and ongoing maintenance. This can be particularly beneficial in areas like Norfolk, where local employment opportunities may be limited.

• Impact on Local Economy: Sustainable homes can lead to a healthier community and reduced costs for local services. Lower energy use and reduced waste can lessen the burden on public services, while improved living conditions can enhance community well-being and productivity.

• Financing Options: Various financing options are available for sustainable homes, including green mortgages, which offer favourable terms for energy-efficient properties. Understanding and leveraging these financial products can make sustainable housing more accessible.

• Market Demand: The increasing awareness of climate change and environmental issues has led to a growing market demand for sustainable housing. Builders and investors who respond to this trend can see economic benefits, including quicker sales and a loyal customer base.

6. Private Investment and Pension Investment in Sustainable Homes

Private Investment

Private investment plays a crucial role in financing sustainable housing projects. With a growing awareness of climate change and environmental issues, many private investors are seeking opportunities that align with sustainability goals. Investors are increasingly attracted to sustainable homes due to:

Social Responsibility: Many private investors prioritise environmental, social, and governance (ESG) criteria in their investment decisions. Sustainable housing projects often meet these criteria, making them more appealing for ethical investment portfolios.

Financial Returns: Sustainable homes can lead to higher long-term returns due to lower operational costs, increased property values, and growing demand for eco-friendly living spaces. Investors recognise that sustainable properties can provide stable rental income and appreciation over time.

Risk Mitigation: Investing in sustainable homes can help mitigate risks associated with climate change and regulatory changes. Properties that are energy-efficient and resilient to environmental hazards are less susceptible to market volatility.

Crowdfunding and Community Investment: New platforms allow for crowdfunding sustainable housing projects, allowing individual investors to contribute to developments that resonate with their values.

Pension Investment

Pension funds are increasingly recognising the importance of sustainable investments as part of their portfolios. The RSA (Royal Society for the Encouragement of Arts, Manufactures and Commerce) has highlighted several key findings regarding pension investments in sustainable housing:

Long-Term Viability: Pension funds typically seek long-term investment strategies. Sustainable housing provides a consistent demand and stability, making it an attractive option for pension fund managers.

Alignment with ESG Goals: Many pension funds are committing to sustainable investment frameworks, aligning their portfolios with ESG principles. This is driven by the growing demand from beneficiaries who prefer investments that have a positive social impact.

Performance Metrics: Studies, including findings from the RSA, indicate that sustainable investments can outperform traditional investments in terms of returns. This is attributed to reduced operational costs, increased market demand, and lower risk profiles associated with sustainable properties.

Collaboration Opportunities: Pension funds are increasingly partnering with private developers and local councils to finance sustainable housing projects. This collaboration can enhance community impact while ensuring financial returns.

Regulatory Support: Governments are increasingly encouraging pension funds to invest in sustainable projects through favourable regulations and incentives, creating a supportive environment for these investments.

In conclusion, both private and pension investments are key drivers for the growth of sustainable housing. The findings from the RSA emphasise the economic viability of sustainable investments, highlighting their potential for higher returns and alignment with modern investment principles.

Return on Investment (ROI) for Pension and Financial Stakeholders in Sustainable Housing Expected ROI for Sustainable Housing Investments

When considering investments in sustainable housing, both pensions and other financial stakeholders can anticipate varying returns depending on a multitude of factors, including location, design efficiency, market demand, and government incentives. Here are some key points regarding expected ROI:

Typical ROI: Investors can expect an ROI ranging from 5% to 10% annually for sustainable housing projects. This range can vary based on specific project characteristics such as energy efficiency, design quality, and integration of renewable technologies.

Time Frame for Returns: The time frame for realising returns on investment in sustainable housing typically ranges from 5 to 15 years. Shorter time frames tend to be associated with rental income from residential properties, while longer time horizons may apply to developments that require extensive capital investment or face regulatory hurdles.

Increased Property Values: Sustainable homes often appreciate faster than traditional homes due to increasing demand for environmentally friendly living spaces. Studies suggest that properties with sustainable features can see value increases of 15% to 30% over a decade.

Operational Savings: Sustainable homes usually have lower operating costs due to energy efficiency and reduced maintenance requirements, which can contribute to overall ROI. These savings can accumulate significantly over time, enhancing the financial returns for stakeholders

Government Incentives: Financial stakeholders can further improve their ROI through government grants, tax incentives, and subsidies specifically aimed at promoting sustainable housing. These financial benefits can reduce initial investment costs and improve cash flow.

Market Demand Trends: As consumer preferences shift towards sustainability, properties that incorporate sustainable features are likely to remain in higher demand. This ongoing trend suggests that the potential for ROI will continue to grow.

Risk Mitigation: Investing in sustainable housing can reduce exposure to regulatory risks associated with climate change and environmental legislation. Properties that adhere to sustainability standards may face fewer restrictions and penalties, contributing to their long-term financial viability.

In summary, pension funds and other financial stakeholders can anticipate robust returns on investments in sustainable housing, supported by ongoing demand, operational savings, and government incentives. A well- structured investment strategy can lead to substantial financial benefits over time.

7. Environmental and Social Factors:

Environment: Sustainable homes contribute positively to the environment by reducing carbon footprints. Incorporating green spaces, utilising rainwater harvesting, and integrating solar power contribute to the overall health of the ecosystem.

Space: Efficient use of space is crucial in urban settings like Norfolk. Designing multi-functional living areas can maximise space for families without increasing the footprint, making homes more suitable for low-income families.

Social: Sustainable housing fosters community by promoting social interaction through shared spaces and community gardens. This encourages neighbourly relationships and a sense of belonging, which are vital for low-income households.

Social Economics: Sustainable homes can contribute to breaking the cycle of poverty by providing stable housing, which is linked to better educational outcomes and health. This investment in housing can stimulate local economies, creating jobs and fostering community resilience.

Designs: Innovative designs that incorporate modular construction, passive heating, and cooling techniques, and local materials can lower construction costs and enhance energy efficiency, making homes more affordable.

Affordable for Low-Income Homes: Strategies like public-private partnerships, government incentives, and community land trusts can help provide affordable housing options for low-income families, ensuring that sustainable homes are accessible.

Home Management: Effective management of sustainable homes includes energy monitoring, community engagement, and maintenance of shared resources to ensure longevity and efficiency of the housing stock. Innovation: The integration of new technologies such as smart home systems, energy-efficient appliances, and sustainable building materials can further reduce costs and environmental impact.

Release of Land: Optimising land use through infill development, mixed-use zoning, and repurposing underutilised properties can increase the availability of land for sustainable housing projects. Long-Term Investment: Sustainable homes provide long-term financial benefits, with increased property values and reduced costs over time. They are a worthwhile investment for both individuals and communities. Council Investment and Planning Needs: Local councils must prioritize sustainable housing in their planning frameworks, including zoning laws, investment in infrastructure, and community engagement initiatives. This requires strategic planning and collaboration with stakeholders. Requirements and Permissions: Obtaining the necessary permissions for building sustainable homes involves navigating local regulations, environmental assessments, and community consultations to ensure compliance and community support. Obtaining the necessary requirements and permissions for sustainable homes in Norfolk involves a multi-step process, typically requiring coordination with the local council and adherence to specific regulations.Pre-Application Consultation: Begin by engaging with the local council through a pre-application consultation. This meeting allows you to discuss your project, understand local policies, and get preliminary feedback on your plans. Site Assessment: Conduct a thorough site assessment that includes environmental impact studies, surveys for protected species, and evaluations of local infrastructure. This information will be essential for the planning application. Planning Application Submission: Prepare and submit a detailed planning application that includes design plans, sustainability assessments, and any required environmental impact assessments. Ensure compliance with Norfolk's local development plan and sustainability guidelines. Public Consultation: After submission, a public consultation period begins where community members can raise concerns or support for your project. Engaging with the community here can be beneficial. Planning Decision: The local council will review your application, considering all feedback and compliance with local policies. They may approve, request modifications, or deny the application.

Building Regulations Approval: Once you receive planning permission, you must apply for building regulations approval to ensure that your construction complies with safety and quality standards.

Construction Phase: After obtaining all approvals, you can begin construction. It is advisable to maintain communication with the council during this phase to ensure compliance with all regulations.

Final Inspections and Compliance Checks: Upon completion, the local council will conduct inspections to ensure that the built project adheres to the approved plans and building regulations.

Occupancy Permit: Finally, obtain an occupancy permit which will allow residents to move in legally.

This structured approach ensures that all necessary requirements and permissions are met, facilitating a smoother process for sustainable housing projects in Norfolk.

8. Conclusion

Building sustainable affordable homes in Norfolk is essential for addressing housing shortages while promoting environmental stewardship and social equity. A collaborative approach involving government, communities, and private sectors will be pivotal in realising this vision.

There needs to be a standardisation of the potential sustainable elements and benefits on all aspects of future development. This not only includes the necessity of providing clean and carbon free environment but must be inclusive of all social and business growth plans and communities.

To achieve this a 'sustainable test' must be understood and passed at all stages to avoid creating local plans that note only tackle the Great Yarmouth Borough Council objectives but also create economic models that are in themselves 'self-sustaining' and result in consistent balanced solutions that are developed locally, by local people and businesses.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP261 - JBJ Associates (PDF, 304 KB)(opens new window)

Rep ID: 262 / Respondent: Ormesby St Margaret with Scratby Parish Council Chris Batten

Date Received: 1/31/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Ormesby St Margaret

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: I would like to confirm that the Ormesby St Margaret With Scratby Parish Council has fully considered the plan and has no additional comments

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 263 / Respondent: Norfolk Coast Parternship Adele Powell

Date Received: 1/31/2025

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy OSS1

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Thank you for consulting Norfolk Coast Partnership (NCP) on the above.

Before a Local Plan can be adopted, the Local Planning Authority must first publish a pre-submission version of the plan and invite representations. This gives the public and stakeholders the opportunity to consider if the plan is:

- Legally compliant.

- Sound.

- Complies with the Duty to co-operate.

NCP believes that the Local Plan meets the legal requirements and the duty to cooperate under section 20 of the Planning and Compulsory Purchase Act 2004 and that the Plan is sound in accordance with the National Planning Policy Framework (NPPF).

Overall, NCP are in support of the Local Plan based on the information provided.

Policy OSS1 - Housing Growth and Location: We note that the housing requirement for the borough over the period 2024 to 2041 is 6,460 homes. Of those homes 2,515 homes already have planning permission, so the Local Plan allocates 4,028 homes. NCP supports the selection of allocated sites outside of the National Landscape. We do note however that six allocation sites are proposed on the edges of Martham, which could increase recreational pressure on the National Landscape, but the impact will likely be minor.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 264 / Respondent: Norfolk Coast Parternship Adele Powell

Date Received: 1/31/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT6

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons:

Thank you for consulting Norfolk Coast Partnership (NCP) on the above.

- Legally compliant.

- Sound.

- Complies with the Duty to co-operate.

Overall, NCP are in support of the Local Plan based on the information provided.

Policy NAT6 - Norfolk Coast National Landscape and the Broads: NCP welcomes the inclusion of Policy NAT6 - Norfolk Coast National Landscape and the Broads. Specifically, we welcome the reference to the National Landscape's Management Plan and that 'Development proposals should seek to protect, conserve, and enhance these valued landscapes, their scenic beauty and their settings.' We also note that the supporting text of the policy states that Local Authorities have a legal duty to seek to further the statutory purpose of conserving and enhancing the natural beauty of National Landscapes and National Parks during plan making and decision-taking on individual developments

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 265 / Respondent: Norfolk Coast Parternship Adele Powell

Date Received: 1/31/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT9

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons:

Thank you for consulting Norfolk Coast Partnership (NCP) on the above.

- Legally compliant.

- Sound.

- Complies with the Duty to co-operate.

Overall, NCP are in support of the Local Plan based on the information provided.

Policy NAT9 - Dark Skies: NCP welcomes the inclusion of Policy NAT9 - Dark Skies and the criteria set out within the policy. We note that the part of the National Landscape that falls within Great Yarmouth falls within Dark Sky Zone 1. The policy notes that external lighting in this area should be avoided. The policy also states: 'Proposals where external lighting is sought in Zones 1 and 2 should include a full lighting strategy scheme that provides information about layout and beam orientation, a schedule of the light equipment proposed including luminaire type, mounting height, aiming angles, colour and lumen unit levels along with an assessment of any impacts on nearby ecological and residential receptors. Such schemes should demonstrate that there will be no significant adverse effects on the visibility of the night sky or its intrinsically dark landscapes.'

NCP are happy with the inclusion of Policy NAT9. However, we recommend a few amendments to the policy, to better avoid any impacts on wildlife. These are as follows:

- Do not illuminate ecologically sensitive areas.

- Avoid illuminating trees and plants.

- Survey area for bat and bird species.

- Do not directly illuminate bat roosts, foraging areas or bird nests.

- Avoid illuminating water or reflective surfaces.

- Use colour temperature, CCTs, ideally 2200K which is the least impactful for invertebrates.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 266 / Respondent: Norfolk Coast Parternship Adele Powell

Date Received: 1/31/2025

Section of the Plan: 14

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CLC1

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Thank you for consulting Norfolk Coast Partnership (NCP) on the above.

- Legally compliant.

- Sound.

- Complies with the Duty to co-operate.

Overall, NCP are in support of the Local Plan based on the information provided.

Policy CLC1 - Coastal Change Management: This policy defines the Coastal Change Management Area within the Borough, which includes part of the National Landscape. This policy is supported as it notes that development within this area will be carefully managed. Furthermore, the policy states that permanent new residential development, including proposals for conversions, replacement dwellings and change of use will not be permitted within the Coastal Change Management Area.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 267 / Respondent: First plan on behalf of National Grid Property Holdings

Date Received: 1/31/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB9

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Introduction

We are instructed on behalf of our client, National Grid Property Holdings (NGPH) to submit representations in respect of the Great Yarmouth Pre-Submission Local Plan (Regulation 19) which is on consultation. NGPH is the landowner and promoter of the Former Gasworks and Gasholder site at Admiralty Road, Great Yarmouth, NR30 3DR, herein referred to as 'the site'. Representations were, also submitted to the Great Yarmouth First Draft Local Plan (Regulation 18) on 8 May 2024, the Great Yarmouth Local Plan Options Consultation and Further Call for Sites on 17 February 2023 and to the Great Yarmouth Design Code consultation draft SPD on 7 September 2023. The representations sought to identify the site for re-development and alternative uses and for ease of reference, copies of the representations are provided at Appendix 1, 2 and 3 of this letter.

Background

Gasholders are no longer operational, as gas can be stored in pipework underground. This means that many sites, comprising gasholder stations and former gasworks facilities, are no longer in use. Instead, they provide an opportunity for alternative development.

The Gasworks, dating back to the mid-1880s, is located at the intersection with Admiralty Road and Barrack Road, with the full extent of the landholding encompasses circa 1.2ha in total. The eastern portion extends to circa 0.4ha and features the Grade II Listed Gasholder. The western portion of the site includes an expansive area of open storage with a separate access off South Denes Road. The site is predominantly laid to hardstanding and bare ground with ephemeral / short perennial vegetation. The surrounding area features residential properties to the north and east with commercial and industrial uses to the south and west. The site is located 400m west of Yarmouth beach and 200m east of the River Yare, close to the new Third River Crossing.

Permission was secured for the demolition of the non-listed gasholder (ref: 06/22/0102/DM) on 17 March 2022 and works have been completed. Planning permission and listed building consent has also been granted for the refurbishment of the listed gasholder frame and removal of the gasholder tank on 26 April 2024 (refs: 06/23/0522/F & 06/23/0523/LB).

Representations

The Great Yarmouth Pre-Submission Local Plan Consultation document (Regulation 19) includes a site-specific policy for the gasholder site under Policy URB9 'Former Gasholder Site, Admiralty Road, Great Yarmouth' (formerly Policy URB7 in the Regulation 18 consultation). NGPH welcome and strongly support the site-specific policy which seeks to encourage alternative uses at this site.

NGPH acknowledge the comments made by the Council in The Local Plan Consultation Statement published alongside the emerging local plan of how our representations have been taken into account. It is understood that the Council consider the types of uses in Policy URB9 to be appropriate in the context of the challenging viability of the brownfield site and that uses such as retail or non-residential are unlikely to be viable on the site. It is acknowledged that the Council has taken on board the minor wording amendments to criteria 'd' of the policy in line with our previous recommendations and this is welcomed by NGPH.

However, as mentioned in our previous representations, NGPH would welcome as wide range of uses as possible at this site to encourage its development. The site has been actively marketed for over a year, for all uses, and there has been little to no interest for any type of development. There are significant site-specific abnormal costs associated with this site through several millions of pounds for the partial dismantling and refurbishment of the listed gasholder, plus remediation and other groundwork-related costs, therefore it is essential that the policy is as flexible as possible regarding residential density and alternative, future uses, to encourage future development. In addition, it is imperative that development can co-exist alongside retained listed structures, subject to detailed design considerations, viability and, of course, regard to the designated heritage asset, both in terms of retention of the asset and enhancing its setting.

There is a need to create a balance between maintaining the listed gas holder and to ensure that the policy wording for the wider site allows for various types of viable development uses to come forward, otherwise it will be difficult to maintain the heritage asset.

Therefore, based on the need to provide a range of uses to ensure a future, viable use for the site and to take into consideration relevant market signals (Paragraph 32 of the National Planning Policy Framework (2024)), we request that the additional wording put forward in our previous representations are carried forward to emerging policy URB9 to encourage this brownfield site to come forward for development.

The changes are not extensive, but we suggest the following amendments in red text to the current draft wording of Policy URB9 to maximise the chance of alternative, future use:

"Policy URB9 - Former Gasholder Site, Admiralty Road, Great Yarmouth

Land at the former Gas Holder Site, Admiralty Road, Great Yarmouth (1.21 hectares) as identified on the Policies Map is allocated for mixed use including residential development to accommodate a minimum of 50 dwellings, retail and / or other appropriate alternative uses, community uses and open space. The site should be developed in accordance with the following site-specific criteria:

a) The housing will be developed at a density of a minimum of approximately 55 dwellings per hectare, having reserved approx. 0.3 hectares for the Gasholder, community uses and open space.

b) A minimum of 10% of the housing should be provided as affordable housing unless it can be demonstrated through the submission of a site-specific financial viability assessment that the development would be unviable.

c) The design of the development must accord with the borough wide design requirements, and criterion CHA5 of the Design Code (Appendix 1).

d) The Grade II listed Gasholder frame must be protected. A Heritage Impact Assessment accompanied by an Archaeological Field Evaluation of the site will be required. Development should be designed to retain the dominance of the Gasholder frame and ensure that long distance views of the structure as a key part of the Great Yarmouth skyline are maintained.

e) Provide a safe and appropriate access and necessary highway improvements to integrate into the existing pedestrian, cycling and road networks including:

i. Vehicular access at South Denes Road;

ii. Footway provision along Sutton Road; and

iii. Enhanced footway provision along Barrack Road.

f) At least 0.12 hectares of open space should be provided on-site to meet children's play space and informal amenity green space needs. This should be located in or around the Gasholder frame structure.

g) Deliver biodiversity net gain in accordance with Policy NAT3.

h) Submission of a site-specific Flood Risk Assessment demonstrating how the site can be developed and occupied safely."

Conclusion

NGPH welcome the recognition that is given to the gasholder site in the draft version of the local plan and the proposed changes made to part d of Policy URB9. NGPH are committed to finding an alternative use for this important brownfield site.

As set out above, NGPH request some minor alterations to the wording of Policy URB9 to take into consideration site-specific circumstances, pending abnormal costs associated with readying the site for alternative use and current market conditions.

We trust the above representations will be taken into account as part of the draft local plan and NGPH would welcome a discussion with officers to discuss these representations further at the appropriate time.

Suggested Modifications: See Question 5

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP267 - National Grid (PDF, 1 MB)(opens new window)

Rep ID: 268 / Respondent: Norfolk County Council Strategy and Transformation Team

Date Received: 1/31/2025

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy OSS1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: 2.1. Norfolk County Council supports the Plan's approach of planning for local housing need in line with government policy for the period 2024-2041. This is in line with Agreements 1 and 11 of the Norfolk Strategic Planning Framework.

2.2.Norfolk County Council also supports the overall distribution of housing that focuses growth in:

•The urban area of Great Yarmouth, Gorleston and Bradwell - 45% of housing growth

•Caister-on-Sea - 20% of housing growth

•Villages - 35% of housing growth

2.3.This strategy remains broadly consistent with the existing settlement hierarchy contained in the adopted Local Plan and focuses the greatest amount of growth in the most sustainable locations, namely the urban areas of Great Yarmouth, Gorleston and Bradwell, which have good access to services, facilities, employment opportunities and infrastructure.

2.4. It is however noted that a significant proportion of growth is also allocated to villages. Whilst Norfolk County Council recognises that villages can play an important role in meeting the borough's overall housing needs, it needs to be recognised that there can be additional costs for the County Council related to such growth. In particular, where there is no school within safe walking distance, permanent public investment in home-to-school transport. It is essential that adequate provision is made within meet such costs, which are the direct consequence of development. Further comments on home to school transport have been made below in relation to the local plan's policy on Infrastructure Provision.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 269 / Respondent: Norfolk County Council Strategy and Transformation Team

Date Received: 1/31/2025

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy OSS4

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Policy OSS4 - Infrastructure Provision

2.5. Norfolk County Council (NCC) remains broadly supportive of Policy OSS4 (Infrastructure Provision). Nonetheless, NCC is considers that, as currently drafted, the policy is not "Sound".

2.6. In its representations to the Great Yarmouth Draft Local Plan - Regulation 18 - Consultation in May 2024, NCC had requested that specific reference to education was included in policy OSS4, in addition to specific references to transport infrastructure. NCC notes the LPA's responses to NCC's previous representations: that, other than in relation to new Primary School at Jack Chase Way, Caister and a new Special Educational Needs school at Caister, education should be considered to fall within the wider references to

infrastructure in the policy.

2.7. Paragraph 99 of the National Planning Policy Framework (NPPF), December 2023, sets out that local planning authorities should take a proactive, positive and collaborative approach to making sufficient schools places available and "give great weight to the need to create, expand or alter schools through the preparation of plans and decisions on applications".

2.8. NCC remains of the view that not specifically referring to education within the policy, reflecting the fact that the primary, and possibly only, available source of funding to create additional places will be developer contributions, fails to give great weight to the need to create, expand or alter school and is therefore inconsistent paragraph 99 of the NPPF.

2.9. NCC therefore considers that in order to ensure that the plan is "Sound" the importance of Education as a priority for funding should be specifically referred to alongside the Great Yarmouth Transport Strategy and Local and Cycling Walking and Infrastructure Plan and in addition to the two individual education schemes mentioned. This will ensure that the policy is unambiguous about the importance of funding education provision and that appropriate weight is given to education within the plan and subsequent decision-making process.

2.10. In addition to the above, in its representations to the Great Yarmouth Draft Local Plan - Regulation 18 - Consultation in May 2024, NCC also raised concerns in respect of whether Great Yarmouth's approach to infrastructure delivery could compromise the delivery of education provision.

2.11. As has already been set out, paragraph 99 of the NPPF, December 2023, sets out that local planning authorities should "give great weight to the need to create, expand or alter schools through the preparation of plans and decisions on applications". In terms of funding for school places, The Department for Education (DfE) in its publication: Securing developer contributions for education, August 2023, clearly states that it "expects local authorities to seek developer contributions towards school places that you create to meet the need arising from housing development". It also states that the DfE's Basic Need grant, free schools programme and other capital funding do not negate housing developers' responsibility to mitigate the impact of their development on education". Indeed, it is NCC's view that it is unlikely that alternative sources of funding, other than developer contributions, can realistically be relied upon to fund the expansion of schools where it is necessary to meet the needs of growth. Again, this clearly establishes the primacy of developer contributions in ensuring adequate school places are made available.

2.12. In respect to the scale of funding needed, Great Yarmouth's assessment of Infrastructure Needs calculates that contribution for essential education

(including early years) infrastructure alone will be in excess of £27M. This estimate only includes the cost of additional place provision for early years, primary and secondary education.

2.13. In respect of the Great Yarmouth's assessment of infrastructure needs, in its representations to the Great Yarmouth Draft Local Plan - Regulation 18 -

Consultation in May 2024, NCC identified that a revision to our planning standards was due to be published in June/July 2024. These updated standards were published in June 2024 and included standards on Home to School Travel Contributions. Paragraph 45 of the Department for Education (DfE) in its

publication: Securing developer contributions for education, August 2023, sets out that where there is no suitable solution for sustainable access to school, but a local planning authority is still minded to approve a development, that contributions towards the cost of home-to-school transport can be sought. Paragraph 45 also notes that "home-to-school transport receives no ringfenced funding of its own".

2.14. Paragraph 41 of the Department for Education (DfE) in its publication: Securing developer contributions for education, August 2023, sets out that local plans should set out the expectation for contributions from development towards infrastructure. NCC's Planning Obligation Standards1, June 2024, set out the County Council's proposed approach to the calculation of home-to- school transport contributions. Paragraph 059 of the Planning Practice Guidance on Plan-Making sets out governments recommendation that "when preparing a plan, strategic policy making authorities use available evidence on infrastructure requirements to prepare an Infrastructure Funding Statement, which sets out the anticipated funding from developer contributions, and the Norfolk County Council Planning Obligation Standards, June 2024. choices local authorities have made about how these contributions will be used". The purpose of this IFS is to "demonstrate the delivery of infrastructure through the plan-period".

2.15. Paragraph 20 of the NPPF, December 2023 sets out that strategic policies should make sufficient provision for, amongst other things, community facilities such as education. Paragraph 31 sets out that all policies should be underpinned by relevant and up-to-date evidence. Paragraph 35 (c) explains that for a plan to be sound it must be deliverable over its plan period. In Norfolk County Council's view, the assessment of whether a plan is deliverable must include a demonstration that there is a reasonable prospect that the infrastructure on which new housing development relies can also be delivered.

2.16. In regard to infrastructure, NCC welcomes the work the local planning authority has done in completing its infrastructure assessment to support the plan-making process. NCC also accepts that this has gone a significant way towards fulfilling the local planning authority's obligations in terms of assessing the need for infrastructure. However, in this instance, NCC has not been able to establish that any assessment has been made of the potential impact of the plan on the need for home-to-school transport and what the associated costs might be, or how such costs would be met. On this basis, NCC has not been able to establish that Policy OSS4 is underpinned by relevant and up-to-date evidence as required by Paragraph 31 of the NPPF, as a major potential infrastructure cost for education appears to be absent. NCC's comments on sites within this representation identifies a number of incidences where there is the potential for home-to-school transport costs to be generated. Whilst this should not be considered an exhaustive list it provides clear evidence of the potential demand for services.

2.17. NCC also welcomes the work undertaken by the LPA in distinguishing between the infrastructure it considers essential and that which it considers desirable. NCC supports the conclusion that education infrastructure should be regarded as essential infrastructure. However, in their Draft CIL Statement of Legal Compliance the LPA have identified a substantial funding gap of circa. £35M. This has been identified between the total cost of infrastructure and CIL income (excluding zero rated sites, non-CIL). In this regard, NCC notes that there seems to be a disparity between the total estimated infrastructure costs set out in the Draft CIL Statement of Legal Compliance, October 2024 and in the Local Plan Infrastructure Needs Study, November 2024. Specifically, the Infrastructure Needs Study identifies a total infrastructure cost of £63,250,239, whereas the Statement of Legal Compliance assesses the total estimated cost of infrastructure to be £60,546,239. This may be explained by the fact that the Statement on Legal Compliance is dated before the Infrastructure Needs Study, but also indicates that the infrastructure funding gap is likely to be even greater than that identified in the CIL Statement of Legal Compliance. NCC's also notes that the total cost of essential education infrastructure alone will significantly exceed expected CIL income. The stark reality of this situation reinforces NCC's concerns about the availability of funding for education.

2.18. NCC has not been able to identify any assessment that demonstrates

how infrastructure will be delivered throughout the plan period, for example an Infrastructure Funding Statement prepared in accordance with the Planning Practice Guidance on plan-making. As set out in Paragraph 059 of the Planning Practice Guidance on Plan-Making, such an assessment should set out the anticipated funding from developer contributions, and the choices local authorities have made about how these contributions will be used. In NCC's

opinion, this should not be limited to identifying that infrastructure to be delivered through CIL and S106 but should also include: an assessment of all the contributions (CIL and residual S106) that are expected to secured through development; an assessment of alternative funding streams for essential and desirable infrastructure that might reasonably be available; an assessment of what such alternative sources of funding might mean in terms of reducing the overall funding gap, and ultimately demonstrate how expected contributions will be prioritised to demonstrate a reasonable prospect that the identified essential infrastructure can be delivered in a timely manner to support planned growth.

2.19. The apparent absence of such an assessment is of a significant concern to NCC, as the extent of the identified funding gap appear to present a material risk that adequate funding will not be able to be secured to meet the needs of essential education infrastructure to support planned growth, particularly as it appears that in many incidences Gt Yarmouth Borough Council are not intending to use S106 obligations even where it is necessary to secure essential infrastructure.

2.20. In order to address these concerns, and ensure the plan is Sound in accordance with the provisions of the NPPF, NCC considers that additional evidence is needed, alongside further modifications to policies. This evidence and modifications are as follows:

• A review of the Local Plan Infrastructure Needs Study that includes an assessment of the likely need for home-to-school transport contributions where planned growth is not within statutory distances of schools.

• The preparation of an Infrastructure Funding Statement, or document of similar purpose, which demonstrates - with a reasonable degree of certainty - the delivery of the infrastructure needed to support development across the plan period. In the view of NCC, and in light of the reliance on developer contributions to fund in education infrastructure, this will need to prioritise education contributions as a first call on CIL income.

2.21. The preparation of this additional evidence to support the examination of the plan is necessary to demonstrate, through its examination, that the policies of the plan are underpinned by relevant and up-to-date evidence, that its strategic policies make sufficient provision for community facilities and that those policies are deliverable over the plan period.

• An amendment to the penultimate paragraph of Policy OSS4 - Infrastructure Provision as follows (amendments shown in underlined and emboldened text):

"Off-site infrastructure will generally be funded by the Community Infrastructure Levy, with the exception of development on land allocated by Policy CAS1 and the defined zero-rated brownfield sites within the urban area, where section 106 planning obligations will instead be used. S106 obligations will also be used in addition to Community Infrastructure Levy contributions where it is necessary to ensure the delivery of essential infrastructure. In determining which schemes will be allocated Community Infrastructure Levy funding, priority will be given to the funding of identified essential infrastructure schemes, such as education infrastructure. On-site ..."

2.22. This amendment is necessary to ensure that the strategic policies of the plan are Sound by ensuring they are effective in making sufficient provision for community infrastructure, in this particular case education, and are consistent with the NPPF in giving great weight to the need to create, expand or alter schools through the preparation of plans and decisions on applications. The amendment also establishes a clear position that the use of S106 alongside CIL will be used where necessary to secure essential infrastructure, this will ensure that the policy is consistent with the requirements of Paragraph 20 of the NPPF and that essential infrastructure is provided alongside development.

• The inclusion of an additional appendix within the Local Plan that details the essential and desirable infrastructure requirements that have been identified as being necessary to support planned growth. This could usefully include an indication of the expected timing for when essentially and desirable infrastructure is needed to support planned growth.

2.23. This amendment is necessary to ensure that the plan is effective in aligning growth and infrastructure in line with the presumption in favour of sustainable development. This will also ensure that the modifications NCC consider are necessary to Policy OSS4 are clear and unambiguous, so it is evident how a decision maker should react to development proposals.

• An amendment to paragraph 3.21 of the supporting text to Policy OSS4 to read as follows (amendments shown in underlined and emboldened text):

The provision of new and improved infrastructure is essential to ensure that new development in the Borough is sustainable. Infrastructure includes a wide range of facilities and services including schools (including provision for Special Education Needs), the provision of home-to-school transport, medical facilities ...

2.24. This amendment is necessary to ensure that the interpretation of the education/schools infrastructure includes the provision of Special Educational Needs provision and the provision of home-to-school transport and thus that the policies of the plan are Sound by ensuring they are effective in making sufficient provision for community infrastructure in accordance with the policies of the NPPF and that the policies are clearly written and unambiguous.

2.25. NCC would welcome the opportunity to work with Gt Yarmouth Borough Council to agree a statement of common ground, which includes agreed modifications that would address NCC's concerns.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 271 / Respondent: Norfolk County Council Strategic Transport

Date Received: 1/31/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB9

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: The policy for URB9 is that access must be taken from South Denes Road which the highway authority does not support, due to the proximity of the signal junction of the Herring Bridge. Vehicles emerging from the site access would need to cross three southbound lanes to head northbound. Access to the development should be taken from Admiralty Road, rather than South Denes Road.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 272 / Respondent: Norfolk County Council Strategic Transport

Date Received: 1/31/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy REP1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy for the allocation must include the extension of the 40mph speed limit on Mill Road south beyond the site frontage.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 273 / Respondent: Norfolk County Council Strategic Transport

Date Received: 1/31/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB11

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy d. refers to "enhanced foot and cycle connections along Riverside Road and Dock Tavern Lane", however, we do not believe that this policy requirement is achievable without acquiring third party land between the site and Dock Tavern Lane.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 274 / Respondent: Norfolk County Council Minerals and Waste

Date Received: 1/31/2025

Section of the Plan: 1

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:1.13-1.14

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: 4.1. The Minerals and Waste Authority do not consider the Local Plan to be Sound.

4.2. At the Regulation 18 consultation stage we requested that either supplementary text is added to section 1, or the inclusion of a figure similar to Figure 1 in the adopted GYBC Core Strategy recognising that the Minerals and Waste Local Plan also forms part of the Development Plan for Great Yarmouth, not only in terms of minerals and waste development, but for all other development affected by minerals and waste safeguarding.

4.3. The introduction to the Local Plan does not mention Norfolk's Minerals and Waste Local Plan, whereas it does set out the policy context in terms of Neighbourhood Plans, the Broads Authority and the Marine Management Organisation's Plans. Therefore, the introduction to the Local Plan does not clearly set out the planning policy context for decision making for non-minerals and waste development located within minerals or waste safeguarding areas, where planning decisions would be taken by the Borough Council.

4.4. The Local Plan needs to make clear the full planning policy context which is relevant to its decision making and should reflect this in the 'cross boundary matters' section.

4.5. To ensure the plan is sound, and consistent with the NPPF, the introduction should recognise that the Minerals and Waste Local Plan also forms part of the Development Plan for Great Yarmouth, as defined in section 38 of the Planning and Compulsory Purchase Act 2004.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 275 / Respondent: Norfolk County Council Minerals and Waste

Date Received: 1/31/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT3

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: 4.7. Whilst the Minerals and Waste Authority do not consider the Local Plan to be unsound, however it would make the following observations in respect of the policy.

4.8. The contents of Policy NAT3 is noted with regards to the delivery of at least 20% Biodiversity Net Gain by major development proposals and the exceptions to that policy requirement. However, as Great Yarmouth Borough Council is not the Minerals and Waste Planning Authority, the Local Plan Viability Assessment (2023) quite reasonably does not consider whether 20% BNG is viable for minerals or waste development. It is therefore our understanding is that the 20% BNG would not apply to major development that is minerals or waste development. It would therefore be helpful for the supporting text to make this clear.

Suggested Modifications: A modification was suggested to make clear that 20% BNG would not apply to minerals and waste development.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 276 / Respondent: Norfolk County Council Minerals and Waste

Date Received: 1/31/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB20

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Policies URB20, URB21, CAS1, CAS2 and MAR6

4.10. The Minerals and Waste Authority do not consider the following policies to be Sound:

• Policy URB20 - Paragraph 4.204

• Policy URB21 - Paragraph 4.218

• Policy CAS1 - Paragraph 5.25

• Policy CAS2 - Paragraph 5.38

• Policy MAR6 - Paragraph 6.22

included within each relevant site allocation policy "A planning application should be supported by evidence which assesses the quantity and quality of mineral resource. Extraction of minerals prior to development of this site is encouraged where practical and environmentally feasible".

4.12. The Regulation 19 Local Plan does not list the requirement in the policies, but within the supporting text. We are not raising an objection to the policies do not including the mineral safeguarding requirement, noting that the Regulation 18 Consultation Statement said "planning applications will be required to submit evidence which assesses the quantity and quality of mineral resource as required by the adopted and emerging minerals and waste local plan. It is not considered necessary to include the wording within the policy itself and would not prohibit the requirement of such evidence to be submitted with a planning application." The supporting text is however inconsistent with the mineral safeguarding working used for other allocated sites and incorrectly states that the policy does include the requirement.

Suggested Modifications: Suggested to amend the supporting text as "A planning application should be supported by evidence which assesses the quantity and quality of mineral resource. Extraction of minerals prior to development of this site is encouraged where practical and environmentally feasible".

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 277 / Respondent: Norfolk County Council Minerals and Waste

Date Received: 1/31/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB21

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Policies URB20, URB21, CAS1, CAS2 and MAR6

4.10. The Minerals and Waste Authority do not consider the following policies to be Sound:

• Policy URB20 - Paragraph 4.204

• Policy URB21 - Paragraph 4.218

• Policy CAS1 - Paragraph 5.25

• Policy CAS2 - Paragraph 5.38

• Policy MAR6 - Paragraph 6.22

4.11. At Regulation 18, we responded that the site allocation policies do not contain the requirement for minerals safeguarding (where applicable). The Minerals Planning Authority considers that the following wording should be included within each relevant site allocation policy "A planning application should be supported by evidence which assesses the quantity and quality of mineral resource. Extraction of minerals prior to development of this site is encouraged where practical and environmentally feasible".

Suggested Modifications: It was suggested that the supported text is amended to: "A planning application should be supported by evidence which assesses the quantity and quality of mineral resource. Extraction of minerals prior to development of this site is encouraged where practical and environmentally feasible".

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 278 / Respondent: Norfolk County Council Minerals and Waste

Date Received: 1/31/2025

Section of the Plan: 5

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CAS1

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Policies URB20, URB21, CAS1, CAS2 and MAR6

4.10. The Minerals and Waste Authority do not consider the following policies to be Sound:

• Policy URB20 - Paragraph 4.204

• Policy URB21 - Paragraph 4.218

• Policy CAS1 - Paragraph 5.25

• Policy CAS2 - Paragraph 5.38

• Policy MAR6 - Paragraph 6.22

Suggested Modifications: The following modification is required to make the policies list above sound:

Delete '... the above policy requires development on this site will need to address the requirements of Norfolk Minerals and Waste Core Strategy Policy CS16 (or any successor policy)- 'safeguarding' in relation to mineral resources.'

Replace with '... any planning application should be supported by evidence which assesses the quantity and quality of the mineral resource. Extraction of minerals prior to development of this site is encouraged where practical and environmentally feasible.'

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 279 / Respondent: Norfolk County Council Minerals and Waste

Date Received: 1/31/2025

Section of the Plan: 5

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CAS2

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Policies URB20, URB21, CAS1, CAS2 and MAR6

4.10. The Minerals and Waste Authority do not consider the following policies to be Sound:

• Policy URB20 - Paragraph 4.204

• Policy URB21 - Paragraph 4.218

• Policy CAS1 - Paragraph 5.25

• Policy CAS2 - Paragraph 5.38

• Policy MAR6 - Paragraph 6.22

Suggested Modifications: The following modification is required to make the policies list above sound:

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 280 / Respondent: Norfolk County Council Minerals and Waste

Date Received: 1/31/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy MAR6

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Policies URB20, URB21, CAS1, CAS2 and MAR6

4.10. The Minerals and Waste Authority do not consider the following policies to be Sound:

• Policy URB20 - Paragraph 4.204

• Policy URB21 - Paragraph 4.218

• Policy CAS1 - Paragraph 5.25

• Policy CAS2 - Paragraph 5.38

• Policy MAR6 - Paragraph 6.22

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 281 / Respondent: Norfolk County Council Minerals and Waste

Date Received: 1/31/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB24

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Policy URB24

4.15. The Minerals and Waste Authority do not consider Policy URB24 to be Sound.

4.16. Policy URB24 allocates land at Shrublands, Magdalen Road, Gorleston, which is within the defined mineral safeguarding area and underlain with sand and gravel. The allocation is currently unsound as it is inconsistent with national policy in relation to mineral resource safeguarding because mineral safeguarding is not mentioned in the policy or supporting text. Therefore wording must be included in the supporting text to inform potential developers of the need to take mineral safeguarding into account in accordance with the NPPF, current Policy CS16 and its successor Policy MP10 in the Norfolk Minerals and Waste Local Plan; consistent with other relevant site allocations in the Great Yarmouth Local Plan located within a mineral safeguarding area.

4.17. We note that the Regulation 19 Local Plan does not list safeguarding

requirements in the site allocation policies, but within the supporting text. We are not raising an objection to the policy not including the mineral safeguarding on the basis that the Regulation 18 Consultation Statement said "planning applications will be required to submit evidence which assesses the quantity and quality of mineral resource as required by the adopted and emerging minerals and waste local plan. It is not considered necessary to include the wording within the policy itself and would not prohibit the requirement of such evidence to be submitted with a planning application."

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 282 / Respondent: Norfolk County Council Children's Services

Date Received: 1/31/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT3

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: 5.2. NCC Children's Services objects to Policy NAT3 which requires 20% BNG on major planning applications outside of the main settlements and allocated sites. This requirement would prejudice the future operation of school sites. The mandatory requirement for 10% BNG for planning applications introduced in February 2024 has proven very difficult to achieve on school sites without impacting upon playing field provision. In future this will likely cause conflict with Sport England as a statutory consultee as schools undergo the necessary expansion and the amount of unusable playing field for the BNG areas runs out.

5.3. An additional 10% for major applications (20% in total) will further reduce the ability for schools to expand and operate effectively and add additional management and maintenance costs over a 30 year period. In time the BB105 requirements would not be met in terms of required areas for soft/hard play and playing field. Whilst the policy suggests the non-statutory additional 10% could be provided off-site. However, this may result in the County having to enter into a lengthy s106 agreement process to secure the off-site units, endure additional costs to purchase BNG units or, in the worst-case scenario, require the purchase of Statutory BNG Credits at a high expense. These additional costs would reduce the funding for children's education and potentially and cause project delays which would have a detrimental impact on the delivery of education.

5.4. In addition, NCC cannot see that the Local Plan Viability Assessment (2023) which informs the BNG Policy NAT3 has not considered the 20% BNG requirement in relation to the viability of school sites. Consequently, NCC do not consider that this policy is justified, as it cannot be demonstrated that this is an appropriate strategy, taking account of the reasonable alternatives, and based on proportionate evidence.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: https://www.great-yarmouth.gov.uk/media/8358/REP268-323-Norfolk-County-Council/pdf/REP268-323_-_Norfolk_County_Council.pdf?m=1738340467367

Rep ID: 283 / Respondent: Norfolk County Council Children's Services

Date Received: 1/31/2025

Section of the Plan: 13

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy SUT1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: 5.6. NCC consider that the following statement should be added to Policy SUT1:

"it encourages sustainable modes of transport and improved cycling and walking opportunities to local school provision to support communities."

5.7. This will ensure that the plan effective supports healthy lifestyles by promoting sustainable travel to school.

5.8. Developments should be situated in close proximity to local schools and other services in order to support sustainable modes of transport. Where development is permitted in locations where sustainable access to schools is not possible, in line with statutory guidelines, or where schools in a catchment become oversubscribed the impact of home to school transport needs to be mitigated. In such circumstances contributions will be sought from developers to cover the cost of this service. Further comments have been made in this respect in section 2 of this response.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 284 / Respondent: Norfolk County Council Children's Services

Date Received: 1/31/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:4.1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policies URB4, URB5, URB6, URB7, URB8, URB10 & URB11

5.10. Whilst looked at in isolation there is likely to be sufficient capacity to meet the needs for these sites at the primary level, NCC Children's Services are concerned that in combination these sites may exceed available capacity and the capability of local schools to expand. Should schools not be able to accommodate children from planned growth it is likely children will need to travel further than the statutory travel distance in order to get a place and home to school contributions will be required.

5.11. In terms of secondary education, The Infrastructure Needs Study that accompanies the plan indicates that Great Yarmouth Charter can be expanded to meet additional demand from sites URB4-8, 10 C 11. Individually these sites could be accommodated however NCC Children's Services do not consider that the school can be expanded further is additional demands exceed current capacity. For URB11 it is suggested that additional capacity can be made in the wider Gorleston schools. This could lead to additional pressure on those schools and could impact the NCC's responsibility for home to school transport. If children are required to travel further than the statutory travel distance, contributions towards home to school transport costs will need to be made.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 292 / Respondent: Norfolk County Council Children's Services

Date Received: 1/31/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB9

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy URB9 - Former Gasholder Site, Admiralty Road, Great Yarmouth

5.12. This allocation could support numbers at the local primary school ensuring sustainable modes of transport are available for families. Impact on secondary school provision is as set out for sites URB4-8, 10 C 11.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 293 / Respondent: Norfolk County Council Children's Services

Date Received: 1/31/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB21

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy URB21 - Land at Links Road, Gorleston

5.13. This site falls within the Cliff Park Primary catchment and will have improved links to the new Homefield primary school set to be delivered by 2027. This recognises Hopton CP would not have capacity to meet the demand from this and other developments planned.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 294 / Respondent: Norfolk County Council Children's Services

Date Received: 1/31/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB25

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy URB25 - Land off East Anglian Way, Gorleston

5.14. Expansion of the existing primary using the 0.8Ha of land will be useful in order to meet expected future demand. The cost of this expansion would need to come from contributions from the developer in order to mitigate the impact of the development on the school. If the required school expansion cannot be achieved contributions towards home to school transport will be required.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 295 / Respondent: Norfolk County Council Children's Services

Date Received: 1/31/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB26

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy URB26 - Land at Beccles Road, Bradwell

5.15. Additional housing provided by this allocation will support existing schools in the area and will support children obtaining a place at the relocated and expanded school of Homefield Bradwell. Consideration should be given to ensuring safe walking and cycling routes are provided to support children getting to school and other community facilities as appropriate.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 296 / Respondent: Norfolk County Council Children's Services

Date Received: 1/31/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB19

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy URB19 - Beacon Park Housing Allocation, Beaufort Way, Bradwell.

5.16. Add a further criteria to part (c) of the policy to stipulate good pedestrian/cycle links to aid transportation to the school infrastructure within the area.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 297 / Respondent: Norfolk County Council Children's Services

Date Received: 1/31/2025

Section of the Plan: 5

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CAS1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy CAS1 - Land at Nova Scotia Farm

5.17. The northern part of this site could impact capacity at Ormesby based on the proximity and current parental preference decisions of existing residents.

This should be considered when determining applications for the development of the site and mitigation of education impacts

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 298 / Respondent: Norfolk County Council Children's Services

Date Received: 1/31/2025

Section of the Plan: 5

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CAS2

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy CAS2 - Land east of Ormesby Road

5.18. NCC Children's Services welcomes the inclusion of 2.5Ha of land for a special education needs (SEND) school, this is essential infrastructure which is necessary to ensure growing need for SEND provision is met. It is considered that there will be limited impact on surrounding schools and sustainable transport from this allocation site.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 299 / Respondent: Norfolk County Council Children's Services

Date Received: 1/31/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy BEL1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy BEL1 - Land at New Road, Belton

5.19. NCC Children's Services welcome the allocation of site BEL1 as it will support local children numbers and promote sustainable modes of transport to the existing school in close proximity.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 300 / Respondent: Norfolk County Council Children's Services

Date Received: 1/31/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy BUR1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy BUR1 - Land off Louis Dahl Road, Burgh Castle

5.20. NCC Children's Services not that this allocation will support local children getting a place within Moorlands. However, it doesn't provide a suitable walking/cycle route for families in order to travel to the catchment school. Pupils maybe displaced on distance which will require contributions being made to home-to-school transport.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 301 / Respondent: Norfolk County Council Children's Services

Date Received: 1/31/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy FLG1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy FLG1 - Land off Tower Road, Fleggburgh

5.21. In respect of the paragraph 6.42 unless land is made available to allow expansion through the local plan, it cannot be assumed the site can be expanded on land not owned by NCC or the Borough Council. Therefore, it may not be possible to extend the school to accommodate rising demand. Should expansion be necessary, contributions would be needed towards both the purchase of land and the extension of the school. If it is not possible to expand the school the contributions will need to be made to home-to-school transport.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 302 / Respondent: Norfolk County Council Children's Services

Date Received: 1/31/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HEM1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy HEM1 - Land at Yarmouth Road, Hemsby

5.22. If the local school is unable to be expanded to accommodate additional generated through the local plan allocations, contributions would need to be made for home to school transport, these contributions would be necessary in order to accommodate local children in either Winterton or Ormesby

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 303 / Respondent: Norfolk County Council Children's Services

Date Received: 1/31/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HOP2

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy HOP2 - Land at Coast Road, Hopton

5.23. This site is anticipated to deliver a small child yield which the existing primary could meet ensuring it serves its local village population. The proximity and density of this development is in line with the capacity of the existing school.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 304 / Respondent: Norfolk County Council Children's Services

Date Received: 1/31/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy ORM1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy ORM1 - Land at Cromer Road, Ormesby St Margaret & Policy ORM2 - Land at Barton Way, Ormesby St Margaret

5.24. This allocation will support the pupil population, however should there be a delay in delivery to the new school planned in Caister and/or if sufficient places are not able to be provided locally in Hemsby, Martham, which are identified as being potentially constrained in the Infrastructure Needs Study, then overspill from these areas are likely to overspill into Ormesby St Margaret which may mean that sufficient places cannot be provided locally to meet demands. This situation will need to be kept under review as development progresses. NCC would encourage a criteria being added to the policy to require good pedestrian/cycling links to cross Cromer Rd. Such links need to be considered in order to ensure children can safely access the school provision.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 305 / Respondent: Norfolk County Council Children's Services

Date Received: 1/31/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy ORM3

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy ORM3 - Land at Yarmouth Road, Ormesby St Margaret

5.25. NCC Children's Services note that this site is quite isolated from the settlement and will challenge sustainable modes of travel for children. This will likely impact the build-up of traffic in and around the local schools. This allocation will support the pupil population, however should there be a delay in delivery to the new school planned in Caister and/or if sufficient places are not able to be provided locally in Hemsby, Martham, which are identified as being potentially constrained in the Infrastructure Needs Study, then overspill from these areas are likely to overspill into Ormesby St Margaret which may mean that sufficient places cannot be provided locally to meet demands. This situation will need to be kept under review as development progresses.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 306 / Respondent: Norfolk County Council Children's Services

Date Received: 1/31/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy MAR1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy MAR1 - Land South of Repps Road, Martham

5.26. Martham schools is currently 2 forms of entry and expanding further would not be an option based on the organisational structure of the school at this point. Such expansions would only be an option if the necessary contributions were available and the academy trust that operates the school agreed to such a change. All sites do not present suitable sustainable routes to school which may impact the number of car journeys across the area.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 307 / Respondent: Norfolk County Council Children's Services

Date Received: 1/31/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy MAR2

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policies MAR2, MAR3, MAR4 & MAR6

5.27. Collectively the total amount of housing could impact capacity for the school. This may mean families having to seek alternative places. If provision cannot be made at schools with statutory safe walking distances, contributions for Home to School transport will be necessary.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 308 / Respondent: Norfolk County Council Children's Services

Date Received: 1/31/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy MAR3

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policies MAR2, MAR3, MAR4 & MAR6

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 309 / Respondent: Norfolk County Council Children's Services

Date Received: 1/31/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy MAR4

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policies MAR2, MAR3, MAR4 & MAR6

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Date Received: 1/31/2025

Section of the Plan: 14

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CLC2

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: The LLFA has reviewed the Policy CLC2 - Flood Risk Policy. The LLFA recognise that the local plan will be assessed under the previous version of the NPPF under the transitional arrangements for plan-making. However, the LLFA notes that that in the recent NPPF updates (12 December 2024), there is an expanded definition of the SuDS requirements in the NPPF in paragraphs 181 and 182. The LLFA recommends that these should be noted in section 14.33 and 14.34. A review of the updated NPPF paragraph 175 identifies minor changes that the LLFA considers should also be reflected in the local plan policy where appropriate. The LLFA requests the NPPF updates are included in the policies as these will strengthen the local plan policies and ensure that the plan will be consistent with the updated NPPF, which is material for the purposes of decision making from the date of its publication.

The LLFA reminds the LPA of the importance of the Local Plan combined with the LLFA's guidance as was indicated in the Planning Inspectorate Appeal Decision Ref: APP/F2605/W/24/3348080 for Land south of the A47, Swaffham PE37 7XD dated 10 December 2024.

In section 14.32, it is important to note the emergency plan needs to be an "agreed" emergency plan in accordance with the wording of NPPF. The agreement will need to be reached with the relevant Emergency Planning Officer prior to the information being submitted.

In section 14.33 and 14.34, there is no cross referencing to the LLFA's Developer Guidance. It would be relevant to cross reference this guidance as it is considered the Continuation sheet to: FW2024_0934 Dated: 10 January 2025 -2-LLFA's publicly available advice that in accordance with NPPF paragraph 182 states that:

"Sustainable drainage systems provided as part of proposals for major development should take account of advice from the Lead Local Flood Authority".

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 314 / Respondent: Norfolk County Council Lead Local Flood Authority

Date Received: 1/31/2025

Section of the Plan: 0

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Appendix 1 Design Code

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons:

6.6. In Appendix 1 Design Code, the LLFA notes that the latest NAFRA2 data is due to be published shortly in March 2025. This work includes a new coastal erosion zone and updated surface water flood risk mapping. The LLFA suggests that this information is sought in advance from the Environment Agency and Defra to ensure that no conflicts occur between the proposed local plan and the

upcoming national flood risk assessment information.

6.7. In Appendix 1 it could be worth cross referencing CC4 in relation to the

discharge hierarchy for the surface water flood risk management. It is also required by Anglian Water for developers to demonstrate that they have

considered water reuse in accordance with the Sewerage Sector Guidance before water companies are able to consider sewer adoption.

6.8. In CC6, the LLFA requests reference to the requirement of applying the four pillars of SuDS as stated in NPPF Paragraph 182 is made.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 315 / Respondent: Norfolk County Council Public Health

Date Received: 1/31/2025

Section of the Plan: 12

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HEC1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: 7.4. NCC Public Health notes the use of a threshold to ensure that larger developments likely to have significant health impacts undertake a Health Impact Assessment (HIA), however are concerned by the threshold of 500 dwellings. The previous version of the Great Yarmouth First Draft Local Plan used a threshold of 150 dwellings or 5 hectares or more; NCC Public Health notes the increased threshold and wish to question the rationale behind such a significant change. The new threshold of 500 would mean that some developments causing significant impacts on health and wellbeing would not be subject to undertake a HIA, and consequently NCC Public Health would recommend that the threshold is reconsidered.

7.5. On the topic of thresholds, it is worth noting that in practice many developers parcel approved sites into phases, thereby minimising their requirements and responsibilities for (e.g.) HIAs. Regardless of the threshold used, NCC Public Health would suggest considering strengthening the wording so that sites as a whole are assessed against the threshold requiring a HIA, even if phasing plans divide the site into smaller parcels.

7.6. NCC Public Health notes the references to both the Planning in Health Protocol and the Healthy Planning Checklist, particularly in relation to proposals of 10 or more dwellings having "regard" to the Healthy Planning Checklist. NCC Public Health would recommend that the wording is strengthened so that proposals should evidence that they have considered and been informed by the Healthy Planning Checklist.

Suggested Modifications: It was suggested to strengthen the wording so that sites as a whole are assessed against the threshold requiring a HIA, even if phasing plans divide the site into smaller parcels.

It was recommended that the wording is strengthened so that proposals should evidence that they have considered and been informed by the Healthy Planning Checklist.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 316 / Respondent: Norfolk County Council Public Health

Date Received: 1/31/2025

Section of the Plan: 12

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HEC2

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: 7.7. NCC Public Health notes the requirement for developments of certain sizes to ensure the provision of open space. In applying the threshold NCC Public Health would again recommend strengthening the wording to ensure that the total development is assessed against the threshold rather than subdivided phases.

7.8. NCC Public Health also recommends that the Building for a Healthy Life guidance be explicitly referenced in this policy, as it is in HEC1, due to recommendations and best practice examples for incorporating green space into developments.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 317 / Respondent: Norfolk County Council Public Health

Date Received: 1/31/2025

Section of the Plan: 12

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HEC8

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: 7.9. Public Health recognise that the local plan will be assessed under the previous version of the NPPF under the transitional arrangements for plan-making.

However, in regard to hot food and takeaways, the updated (December 2024) National Planning Policy Framework (NPPF) states that:

"S7. Local planning authorities should refuse applications for hot food takeaways and fast food outlets:

a) within walking distance of schools and other places where children and young people congregate, unless the location is within a designated town centre; or

b) in locations where there is evidence that a concentration of such uses is having an adverse impact on local health, pollution or anti-social- behaviour"

7.10. NCC Public Health recommend that this is explicitly incorporated in policy HEC8. This will ensure that the plan will be consistent with the updated NPPF, which is material for the purposes of decision making from the date of its publication. In relation to a), the NPPF does not define "walking distance" and so policy HEC8 presents an opportunity to do so locally.

7.11. Similarly, in the Technical Health and Wellbeing Paper included in the evidence base for the Great Yarmouth Local Plan, NCC Public Health recommended that:

"The Great Yarmouth Local Plan could inffuence alcohol consumption by recognising areas with a high number of licence premises, and potentially limit further licencing or recommend restrictions."

7.12. NCC Public Health's previous response dated 8 May 2024 recommended that Policy HEC7 is more explicit in limiting the density of alcohol licences. In December 2024, the Association of Directors of Public Health (https://www.adph.org.uk/2024/12/alcohol-deaths-spiral/) highlighted the 42% rise in deaths in England caused solely by alcohol in the past four years, and the toll that this has on families, communities, and the healthcare system. As such, both previous recommendations are still valid.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 318 / Respondent: Norfolk County Council Public Health

Date Received: 1/31/2025

Section of the Plan: 12

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HEC7

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: HEC5 - Pollution and Hazards in development / HEC7 - Protection of Amenity

7.13. Both policies HEC5 and HEC7 mention Air Quality/Pollution, particularly in relation to new developments that might contribute to poor air quality. The wording could be strengthened in relation to developments that are sensitive to poor air quality. In the Technical Health and Wellbeing Paper included in the evidence base for the Great Yarmouth Local Plan, NCC Public Health recommended that:

"sensitive developments such as residential areas and schools [are placed] away from regions with poor air quality and design the site layout to minimise their impact"

7.14. Government guidance (https://www.gov.uk/guidance/air-quality--3) states that "air quality may be a material consideration if the proposed development would be particularly sensitive to poor air quality in its vicinity". As such, this

recommendation is still valid.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 319 / Respondent: Norfolk County Council Historic Environment Team

Date Received: 1/31/2025

Section of the Plan: 15

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy DHE3

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: 8.1. Thank you for directly consulting Norfolk County Council Environment Service historic environment specialist advice team regarding the above-mentioned

local plan draft.

8.2. Our comments remain largely unchanged from those given in relation to previous draft of the local plan.

8.3. We are largely satisfied that Policy DHE3 and Appendix 4 recognise the potential importance of below-ground archaeological remains as undesignated heritage assets and have no further comments

Suggested Modifications: Recommendation: None.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 320 / Respondent: Norfolk County Council Fire and Rescue Service

Date Received: 1/31/2025

Section of the Plan: 15

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy DHE1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Background and Context

9.1. Underpinned by statutory obligations within the Fire and Rescue Services Act 2004, the Fire and Rescue National Framework for England provides the overall strategic direction for Fire and Rescue authorities. Within the framework, each authority is required to produce a Community Risk Management Plan (CRMP) that identifies and assesses all foreseeable fire and rescue related risks that could affect its community.

9.2. Each CRMP must demonstrate how prevention, protection and response

activities will best be used to mitigate the impact of risk on its communities. Through local determination of risk and local determination of response standards, it is expected that this will:

• Reduce the number of emergency incidents occurring.

• Reduce death and injury from fire and other emergency incidents.

• Ensures emergency response standards of 10 minutes are met.

• Reduce the socio-economic impacts of fire.

• Protect heritage.

• Safeguard the environment.

• Contribute to the development of stronger, more self-sufficient, and cohesive communities.

• Provide value for money.

9.3. The above legislation imposes a requirement on Fire and Rescue Authorities to ensure efficient and effective fire and rescue provision, and to ensure that the Service contributes effectively to the wider community safety agenda.

Local Plan Comments

facilities and vehicles, and funding for additional equipment based on increased risks such as PV arrays, Domestic Energy Storage Systems and electric vehicle charging points. This also impacts revenue budgets for firefighters, officers, and support staff. NFRS dynamically reallocates resources across the county to meet changes in risk and demand.

9.5. To ensure that NFRS can respond appropriately to the increased risks and demand the supporting text should make it clear that developers will be asked to contribute to fire service vehicles, equipment, facilities and response

provision through the Community Infrastructure Levy, or through s106 agreements, where this meets the legal tests set out in the Community Infrastructure Levy Regulations.

9.6. The capability and availability of water resources to fight fires is a key

consideration for the Service. The provision of public fire hydrants on residential developments is not covered by Building Regulations 2010 (Part B5 as

supported by Secretary of State Guidance 'Approved Document B'). Developers are expected to make provision for fire hydrants to adequately protect a development site for fire-fighting purposes. Design Policy DHE1 should make appropriate reference to the need for fire hydrant provision associated with new development.

9.7. Policy DHE1 of the Local Plan should also have regard to the need for Fire appliance access to all areas of developments, as this is vital for emergency

response and should be in compliance with Building Regulations 2010 (Part B5 as supported by Secretary of State Guidance 'Approved Document B').

9.8. Where residential properties (dwellinghouses) are located more than 45 meters away (furthest point of floorplan) from the closest fire appliance access location British Standard 9991 directs that domestic sprinklers should be installed in

accordance with British Standard 9251 and this will allow a maximum access distance of 90 metres to the furthest point of the floorplan in dwellinghouses with no floor more than 4.5 metres above ground. This is reduced to 75 metres where a floor is over 4.5 metres above ground.

9.9. Norfolk Fire C Rescue Service would expect developers to adhere to the access distances given above or prove comparable safety of occupants should they wish to deviate from these.

9.10. Policy SUT1 (plug in charging facilities), SUT4 (EV charging) and CLC6 (energy efficiency for new developments) - NFRS recognises the need for

Councils to have a positive strategy to promote renewable energy generation in developments.

9.11. Developments which include PV arrays and Domestic Energy Storage Systems (DESS) and should comply with national guidance and Institute of Engineering and Technology (IET) Codes of Practice, and PAS63100:2024.

9.12. Developments including electric vehicle charging points should comply with Secretary of State Guidance 'Approved Document S' and the IET Code of practice: EV Charging Equipment Installation.

9.13. Developers should consult with NFRS both before and during planning stage on safe installation and location within and outside residential dwellings.

9.14. Policy SUT2 (parking provision) should clearly reflect all the above fire safety issues/requirements.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 321 / Respondent: Norfolk County Council Fire and Rescue Service

Date Received: 1/31/2025

Section of the Plan: 13

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy SUT1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Background and Context

9.2. Each CRMP must demonstrate how prevention, protection and response

activities will best be used to mitigate the impact of risk on its communities. Through local determination of risk and local determination of response standards, it is expected that this will:

• Reduce the number of emergency incidents occurring.

• Reduce death and injury from fire and other emergency incidents.

• Ensures emergency response standards of 10 minutes are met.

• Reduce the socio-economic impacts of fire.

• Protect heritage.

• Safeguard the environment.

• Contribute to the development of stronger, more self-sufficient, and cohesive communities.

• Provide value for money.

Local Plan Comments

9.4. New developments as set out in Policies HOU1 - 7, EMP1 and RTC1 - 2 can potentially change the risk profile for the area and increase attendance times to incidents. Increases in population place additional demand on fire and rescue resources, both in terms of the need for additional capital investment in new facilities and vehicles, and funding for additional equipment based on increased risks such as PV arrays, Domestic Energy Storage Systems and electric vehicle charging points. This also impacts revenue budgets for firefighters, officers, and support staff. NFRS dynamically reallocates resources across the county to meet changes in risk and demand.

provision through the Community Infrastructure Levy, or through s106 agreements, where this meets the legal tests set out in the Community Infrastructure Levy Regulations.

9.6. The capability and availability of water resources to fight fires is a key consideration for the Service. The provision of public fire hydrants on residential developments is not covered by Building Regulations 2010 (Part B5 as

9.7. Policy DHE1 of the Local Plan should also have regard to the need for Fire appliance access to all areas of developments, as this is vital for emergency response and should be in compliance with Building Regulations 2010 (Part B5 as supported by Secretary of State Guidance 'Approved Document B').

9.9. Norfolk Fire C Rescue Service would expect developers to adhere to the access distances given above or prove comparable safety of occupants should they wish to deviate from these.

9.10. Policy SUT1 (plug in charging facilities), SUT4 (EV charging) and CLC6 (energy efficiency for new developments) - NFRS recognises the need for Councils to have a positive strategy to promote renewable energy generation in developments.

9.12. Developments including electric vehicle charging points should comply with Secretary of State Guidance 'Approved Document S' and the IET Code of practice: EV Charging Equipment Installation.

9.13. Developers should consult with NFRS both before and during planning stage on safe installation and location within and outside residential dwellings.

9.14. Policy SUT2 (parking provision) should clearly reflect all the above fire safety issues/requirements.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 322 / Respondent: Norfolk County Council Fire and Rescue Service

Date Received: 1/31/2025

Section of the Plan: 13

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy SUT2

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Background and Context

9.2. Each CRMP must demonstrate how prevention, protection and response

activities will best be used to mitigate the impact of risk on its communities. Through local determination of risk and local determination of response standards, it is expected that this will:

• Reduce the number of emergency incidents occurring.

• Reduce death and injury from fire and other emergency incidents.

• Ensures emergency response standards of 10 minutes are met.

• Reduce the socio-economic impacts of fire.

• Protect heritage.

• Safeguard the environment.

• Contribute to the development of stronger, more self-sufficient, and cohesive communities.

• Provide value for money.

Local Plan Comments

provision through the Community Infrastructure Levy, or through s106 agreements, where this meets the legal tests set out in the Community Infrastructure Levy Regulations.

9.6. The capability and availability of water resources to fight fires is a key

consideration for the Service. The provision of public fire hydrants on residential developments is not covered by Building Regulations 2010 (Part B5 as

9.7. Policy DHE1 of the Local Plan should also have regard to the need for Fire appliance access to all areas of developments, as this is vital for emergency

response and should be in compliance with Building Regulations 2010 (Part B5 as supported by Secretary of State Guidance 'Approved Document B').

9.9. Norfolk Fire C Rescue Service would expect developers to adhere to the access distances given above or prove comparable safety of occupants should they

wish to deviate from these.

9.10. Policy SUT1 (plug in charging facilities), SUT4 (EV charging) and CLC6 (energy efficiency for new developments) - NFRS recognises the need for

Councils to have a positive strategy to promote renewable energy generation in developments.

9.12. Developments including electric vehicle charging points should comply with Secretary of State Guidance 'Approved Document S' and the IET Code of practice: EV Charging Equipment Installation.

9.13. Developers should consult with NFRS both before and during planning stage on safe installation and location within and outside residential dwellings.

9.14. Policy SUT2 (parking provision) should clearly reflect all the above fire safety issues/requirements.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 323 / Respondent: Norfolk County Council Fire and Rescue Service

Date Received: 1/31/2025

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy OSS4

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Background and Context

9.2. Each CRMP must demonstrate how prevention, protection and response

activities will best be used to mitigate the impact of risk on its communities. Through local determination of risk and local determination of response standards, it is expected that this will:

• Reduce the number of emergency incidents occurring.

• Reduce death and injury from fire and other emergency incidents.

• Ensures emergency response standards of 10 minutes are met.

• Reduce the socio-economic impacts of fire.

• Protect heritage.

• Safeguard the environment.

• Contribute to the development of stronger, more self-sufficient, and cohesive communities.

• Provide value for money.

Local Plan Comments

provision through the Community Infrastructure Levy, or through s106 agreements, where this meets the legal tests set out in the Community Infrastructure Levy Regulations.

9.6. The capability and availability of water resources to fight fires is a key

consideration for the Service. The provision of public fire hydrants on residential developments is not covered by Building Regulations 2010 (Part B5 as

9.7. Policy DHE1 of the Local Plan should also have regard to the need for Fire appliance access to all areas of developments, as this is vital for emergency

response and should be in compliance with Building Regulations 2010 (Part B5 as supported by Secretary of State Guidance 'Approved Document B').

9.9. Norfolk Fire C Rescue Service would expect developers to adhere to the access distances given above or prove comparable safety of occupants should they

wish to deviate from these.

9.10. Policy SUT1 (plug in charging facilities), SUT4 (EV charging) and CLC6 (energy efficiency for new developments) - NFRS recognises the need for

Councils to have a positive strategy to promote renewable energy generation in developments.

9.12. Developments including electric vehicle charging points should comply with Secretary of State Guidance 'Approved Document S' and the IET Code of practice: EV Charging Equipment Installation.

9.13. Developers should consult with NFRS both before and during planning stage on safe installation and location within and outside residential dwellings.

9.14. Policy SUT2 (parking provision) should clearly reflect all the above fire safety issues/requirements.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP268-323 - Norfolk County Council (PDF, 271 KB)(opens new window)

Rep ID: 324 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:General

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Natural England has reviewed the Regulation 19 consultation Pre-Submission Document of the Great Yarmouth Local Plan together with the Habitats Regulations Assessment (HRA) and Sustainability Appraisal (SA). Please note that we have not provided comments on all policies, but only those which have most influence on environmental issues. Natural England has no comment to make on the policies not covered in this response.

It is Natural England's advice that the Local Plan could currently be considered unsound due to no mention in policies about protecting/avoiding best and most versatile (BMV) soils or suitable management of soils. Paragraph 180 of the National Planning Policy Framework (NPPF) (September 2023) states that "Planning policies and decisions should contribute to and enhance the natural and local environment by: a) protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils (in a manner commensurate with their statutory status or identified quality in the development plan)". This is also paragraph 187 of the revised NPPF (December 2024). Therefore, it is our advice that the Plan is not currently consistent with national policy. Further information on this issue is set out below.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 325 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 2

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Vision and Objectives

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: The Councils' Vision and 12 Objectives are appropriate and aligned with the Three pillars of sustainable development. We believe that there should be a strategic approach to the protection and enhancement of the natural environment, including providing biodiversity net gain (BNG) and enhancing and improving connectivity of green infrastructure. Natural England welcomes Objectives 9, 10 and 11.

Natural England welcomes the inclusion of new and improved open spaces in the Vision (paragraph 2.3). In line with our Green Infrastructure Framework we would like to see this broadened to "new and improved open spaces and wider green and blue infrastructure to benefit the health and wellbeing of residents provide natural flood management, improvements to air and water quality and deliver multifunctional benefits to people and wildlife". Natural England considers that your Authority should do more to retain and develop a specific set of policies for green infrastructure and we encourage you to incorporate the principles and standards in the Green Infrastructure Framework within your plan.

Further advice on green infrastructure and the Framework is provided later in this letter. Natural England welcomes the Vision for waterfronts and seafronts in Great Yarmouth and

Gorleston, but we advise that this includes the King Charles III England Coast Path National Trail. This is an important heritage asset giving people access to these areas, as well as commitment to well-designed new development which conserves and enhances it, and the corridor of coastal margin through which it runs.

We would like to see explicit mention of green infrastructure in Objective 6 as many would not understand that this is an important component of Great Yarmouth's infrastructure. We advise it is revised to read "Objective 6 - To improve the quality and provision of all types of infrastructure, including green infrastructure".

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 326 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy OSS1

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Natural England supports a targeted approach to delivering the majority of new development within existing urban areas

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 327 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy OSS3

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Natural England supports this policy in protecting settlements, undeveloped land and high-grade agricultural land from urban and suburban sprawl. This policy approach also protects the wider countryside and landscape including the Broads National Park and Norfolk Coast National Landscape by protecting gaps between settlements.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 328 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy OSS4

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Natural England welcomes the reference in the policy to the Norfolk Green Infrastructure and Recreational Avoidance and Mitigation Strategy (GIRAMS) of which contributions will be secured through suitable legal obligations.

However, we advise that this policy should be broadened to include provision of green infrastructure under the strategic infrastructure heading. Well-designed green infrastructure can deliver multiple functions supporting people's mental and physical health, encouraging active travel, cooling urban areas during heat waves, attracting investment, reducing water run-off during flash flooding, storing carbon, and providing sustainable drainage. Natural England's GI mapping tool can be used to highlight areas of deprivation with poorer health outcomes. There is a significant under-provision of accessible greenspace in Great Yarmouth and Gorleston, Hemsby and parts of Caister-on-Sea which correspond to areas of deprivation with poor health outcomes.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 329 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:General

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Natural England advised in our response to the First Draft Local Plan Consultation (our ref 469676, dated 8 May 2024) that we had reservations about increased recreational pressure from development and the need for high-quality green infrastructure to retain recreation within the local area, away from designated sites of importance to biodiversity (this includes all international sites (Special Areas of Conservation, Special Protection Areas, and Ramsar sites), national sites (Sites of Special Scientific Interest) and locally designated sites including Local Wildlife Sites). Many of the site specific polices propose very small areas of green infrastructure which may not mitigate impacts to designated sites along the coast although there is a 11.33ha Country Park proposed at Nova Scotia Farm in Policy CAS1 (page 106).

Large development sites may also require bespoke mitigation measures delivered within the designated sites identified, such as the provision of dog waste bins, or improvements to site-based interpretation. Consideration should be given to principles of healthy design and active design.

Useful tools to promote integration of nature and green infrastructure into design and quality of green space include Building with Nature and the Green Flag Award. The Green Infrastructure Standards can also be used to see if this adequately addresses the need for space in the area with the aim that all residents should have access to greenspace within a 15-minute walk of where they live.

Natural England may be able to provide guidance on the measures we consider most effective to achieve this goal through our Discretionary Advice Service.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 330 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT3

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: BNG is mandatory for the majority of Town and Country Planning Act developments under the Environment Act 2021. Developers will need to deliver a minimum 10% biodiversity net gain. This means they must provide 110% of the biodiversity value found on the site prior to their development. Natural England supports the individual site policies to deliver an on-site BNG in accordance with Policy NAT3 and Open Space, Policy HEC2 and in line with the NPPF paragraph193 d). On-site BNG is preferable but as some sites will be unable to deliver this, Natural England supports off-site BNG delivery where required and this could potentially link to the emerging Local Nature Recovery Strategy (LNRS).

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 331 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT6

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Landscape

Many of the allocated sites are adjacent to the Broads National Park. A new consideration for this Plan is Section 245 (Protected Landscapes) of the Levelling Up and Regeneration Act 2023. This "places a duty on relevant authorities in exercising or performing any functions in relation to, or so as to affect, land in a National Park, the Broads or an Area of Outstanding Natural Beauty [AONB] ("National Landscape") in England, to seek to further the statutory purposes of the area. The duty applies to local planning authorities and other decision makers in preparing development plans, making planning decisions on development and infrastructure proposals, as well as to other public bodies and statutory undertakers in undertaking their functions''.

Defra have released ' Guidance for relevant authorities on seeking to further the purposes of Protected Landscapes' (December 2024) and, in accordance with that guidance, Natural England advises that:

• the duty to 'seek to further' is an active duty, not a passive one. You must take all reasonable steps to explore how the statutory purposes of the Protected Landscapes (the Broads National Park, and Norfolk Coast National Landscape) can be furthered;

• The new duty underlines the importance of avoiding harm to the statutory purposes of a Protected Landscape and also to seek to further the conservation and enhancement of a Protected Landscape. That goes beyond mitigation and like-for-like measures and replacement. You must be able to demonstrate with proportionate, reasoned and documented evidence what measures can be taken to further the statutory purpose;

The proposed measures to further the statutory purposes of a Protected Landscape, should explore what is possible in addition to avoiding the effects of the development, and should be appropriate, proportionate to the type and scale of the development and its implications for the area and effectively secured. Natural England's view is that the proposed measures should align with and help to deliver the aims and objectives of the Broads National Park and Norfolk Coast National Landscape statutory management plans, which is reinforced in the Defra guidance. The relevant teams in the Broads National Park and Norfolk Coast National Landscape should be consulted.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 332 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:General

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Agricultural Land

Many of the policies for rural allocated sites state that land is currently in agricultural use but the grade has not been specified. Only in policy MAR4 (Martham) has the land been identified as Grade 1 and 2. Loss of Best and Most Versatile (BMV) (Grades 1, 2 and 3a in the Agricultural Land Classification (ALC)) land has been highlighted as a significant negative effect in the Local Plan SA (March 2024) and also highlighted as an issue in our response to the First Draft Local Plan Consultation .

As stated on page 1 of this letter, the Plan is not currently consistent with Paragraph 180 a) of the NPPF (September 2023) .

It is also not consistent with:

Paragraph 180 b) 'recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services - including the economic and other benefits of the best and most versatile agricultural land'. And:

Footnote 62, 'Where significant development of agricultural land is demonstrated to be necessary, areas of poorer quality land should be preferred to those of a higher quality. The availability of agricultural land used for food production should be considered, alongside the other policies in this Framework, when deciding what sites are most appropriate for development'.

The Plan is also not consistent with NPPF, (December 2024) paragraph 187 b) states that 'Planning policies and decisions should contribute to and enhance the natural and local environment by recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services - including the economic and other benefits of the best and most

versatile agricultural land'.

Footnote 65 of the NPPF also states "Where significant development of agricultural land is demonstrated to be necessary, areas of poorer quality land should be preferred to those of a higher quality".

In our previous response to the first Draft Local Plan Consultation, we advised the following to be included in the policies. These points have not been considered in the Regulation 19 document and therefore we strongly advise that they are considered in order for the plan to align with the NPPF:

Soils

To assist in understanding agricultural land quality within the plan area and to safeguard BMV agricultural land in line with NPPF paragraph 187 b), some strategic scale ALC maps are available. General mapped information on soil types is available as 'Soilscapes' on Magic. Additional information regarding obtaining soil data can be found on the LandIS.

We strongly advise that at a minimum, the Plan includes core policies for:

• the protection of BMV agricultural land; and

• for the protection of and sustainable management of soils as a resource for the future.

• Areas of poorer quality land (ALC grades 3b, 4, 5) should be preferred to areas of higher quality land (grades 1, 2 and 3a).

• Recognise that development has an irreversible adverse impact on the finite national and local stock of BMV land.

• Conforms to NPPF and Planning Practice Guidance (Natural Environment and Minerals).

• Requires detailed ALC surveys to support plan allocations and for subsequent planning applications (for all sites larger than 5 ha). ALC surveys to support plan allocations and for subsequent planning applications for smaller sites (1 - 5 ha) would be welcomed.

• Recognise that development (soil sealing) has a major and usually irreversible adverse impact on soils.

• Soils of high environmental value (e.g., wetland and carbon stores such as peatland, low nutrient soils; or soils of high environmental value in the local context) should also be considered as part of ecological connectivity (Nature Recovery Network / Green Infrastructure).

• Requires soil handling and sustainable soil management strategies based on a detailed assessment of the soil resource based on best practice guidance (for all sites larger than 5 ha), ideally as part of the planning application process for major sites to help inform master- planning, and to safeguard the continued delivery of ecosystem services through careful soil management and appropriate, beneficial soil re-use. Soil handling and sustainable soil management strategies for smaller sites (1 - 5 ha) would be welcomed.

• Reference should be made to Defra's Construction Code of Practice for the Sustainable Use of Soils on Construction Sites

• In addition, for minerals and other temporary forms of development, plans for reinstatement, restoration and aftercare will be required (or for solar, a commitment to do so if the operational life is in decades); normally this will be return to the former land quality (ALC grade)

• Refers to soils issues within relevant policy areas such as, NAT1 Protecting Biodiversity and Geodiversity, HEC3 Protection of Open Spaces and Green Infrastructure, NAT3 Biodiversity Net Gain, NAT7 Landscape Character, NAT8 Strategic Gaps Between Settlements,

Soil is a finite resource which plays an essential role within sustainable ecosystems, performing an array of functions supporting a range of ecosystem services, including storage of carbon and water, the infiltration and transport of water, nutrient cycling, a buffer against pollution and provision of food. In order to safeguard soil resources as part of the overall sustainability of the Plan, it is important that the soil resource is able to retain as many of its important functions as possible. This can be achieved through careful soil management and appropriate, beneficial soil re-use, with consideration on how any adverse impacts on soils can be avoided or minimised.

Sustainable soil management should aim to minimise risks to the ecosystem services which soils provide, through provision of suitable soil handling and management advice. The planning authority should ensure that sufficient site-specific soil survey data is available to inform decision making. To include, for example, assessment of suitability of soil properties for type of landscaping and planting proposed to inform beneficial re-use, appropriate soil management, and drainage, where required.

Further guidance for protecting soils (irrespective of their ALC grading) both during and following development is available in Defra's Construction Code of Practice for the Sustainable Use of Soils on Construction Sites, to assist the construction sector in the better protection of the soil resources with which they work, and in doing so minimise the risk of environmental harm such as excessive run-off and flooding. The aim is to achieve positive outcomes such as cost savings, successful landscaping and enhanced amenity whilst maintaining a healthy natural environment, and we would advise that the Code be referred to where relevant in the development plan.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 333 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 0

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Habitats Regulations Assessment

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Habitat Regulations Assessment (HRA)

As the relevant competent authority, you are required by Regulation 63 of the Conservation of Habitats and Species Regulations 2017 (as amended) to undertake an assessment of projects and impacts to European Sites. Site specific policies should be screened as part of a HRA to determine if the proposal is likely to have a significant effect on the conservation objectives of the European Sites. Depending on the outcome of the screening, it may be necessary to proceed to an appropriate assessment of the policies to assess if the integrity of European Sites will be adversely effected by the policies and if mitigation is required.

The Plan HRA concludes that a likely significant effect on European Sites cannot be ruled out because of the combined impact of residential and tourism development in Norfolk (growth identified within all local authority Local Plans). A strategic mitigation package has been established by Norfolk authorities to mitigate for the impact, known as the Norfolk Green Infrastructure and Recreational Avoidance Mitigation Strategy (GIRAMS), which requires a contribution per dwelling from the developer for each affected application. A project level HRA will therefore required for all development proposals and/or applications scoped into the GIRAMS.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 334 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB22

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Sites of Special Scientific Interest

Where a site is within or close to a Site of Special Scientific Interest (SSSI) a SSSI Impact Assessment may be required alongside the HRA.

• Policy URB22 - Great Yarmouth North Denes Airfield and Policy URB27 - Great Yarmouth Racecourse), will need to address recreational disturbance to Great Yarmouth North Denes SSSI. Paragraph 4.224 only alludes to a HRA. This additional assessment is needed in addition to a HRA as some of the SSSI is outside of the SPA.

• Site allocations (Policies MAR 1 to 6) in Martham will markedly increase pressure on Winterton-Horsey Dunes SSSI, which also extends outside of the underlying SPA/SAC. A SSSI impact assessment will be needed to determine potential mitigation to alleviate recreational disturbance to the site. This would be in addition to the GIRAMS mitigation as there is a possible alone impact

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 335 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB27

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Sites of Special Scientific Interest

Where a site is within or close to a Site of Special Scientific Interest (SSSI) a SSSI Impact Assessment may be required alongside the HRA.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 336 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy MAR1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Sites of Special Scientific Interest

Where a site is within or close to a Site of Special Scientific Interest (SSSI) a SSSI Impact Assessment may be required alongside the HRA.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 337 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy MAR2

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Sites of Special Scientific Interest

Where a site is within or close to a Site of Special Scientific Interest (SSSI) a SSSI Impact Assessment may be required alongside the HRA.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 338 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy MAR3

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Sites of Special Scientific Interest

Where a site is within or close to a Site of Special Scientific Interest (SSSI) a SSSI Impact Assessment may be required alongside the HRA.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 339 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy MAR4

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Sites of Special Scientific Interest

Where a site is within or close to a Site of Special Scientific Interest (SSSI) a SSSI Impact Assessment may be required alongside the HRA.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 340 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy MAR5

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Sites of Special Scientific Interest

Where a site is within or close to a Site of Special Scientific Interest (SSSI) a SSSI Impact Assessment may be required alongside the HRA.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 341 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy MAR6

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Sites of Special Scientific Interest

Where a site is within or close to a Site of Special Scientific Interest (SSSI) a SSSI Impact Assessment may be required alongside the HRA.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 342 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT5

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Drainage and Nutrient Neutrality

It is not explicit in the site allocation policies where a site is in a Nutrient Neutrality catchment. All proposed site allocations that are within the Nutrient Neutrality catchment (see here) should be identified in the Local Plan irrespective of whether the foul water will discharge outside of the Nutrient Neutrality catchment. These will require a HRA to be undertaken informed by a nutrient budget calculation and mitigation where required. Where a site allocation is in the Nutrient Neutrality catchment the site allocation policy should also refer to Policy NAT5 Nutrient Neutrality.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 343 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT9

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Dark Skies

Natural England welcomes the requirement for lighting schemes that will help to conserve dark skies and benefit nocturnal wildlife by reducing visual disturbance. Please refer to our additional advice on Policy NAT9.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 344 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 7

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HOU3

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Housing Planning Policies

Natural England supports Policy HOU3 (Affordable Housing Exception Sites) as this protects the Norfolk Coast National Landscape, and Policy HOU5 (Housing for Older People) as this requires good quality, accessible and functional outdoor amenity space. We also advise that you include either in the policies or summary 'new overnight development located within the nutrient neutrality catchment (as defined by Natural England) must demonstrate how it will address the impacts of potential nutrient loading in accordance with Policy NAT5',and 'Contributions to the Norfolk Green Infrastructure and Recreational Avoidance and Mitigation Strategy will be secured through suitable legal obligations'.

Retail and other Town

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 345 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 7

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HOU5

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Housing Planning Policies

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 346 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 10

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy RTC1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy RTC1 - Retail and Other Town Centre Uses

Natural England supports the Policy which aims to enhance the appearance, safety and environmental qualities of the area.

Natural England advises that the multi-functional nature of green infrastructure makes it integral to this policy. Research has shown how urban green space provides many valuable services, all of which can contribute towards health and wellbeing and economic growth. Natural England advises that urban greenspace should be protected and enhanced where possible. Therefore, we advise that wording within this policy reflects the importance of green infrastructure within the town centres. The policy could also include access to green infrastructure and informal open space in the town, and biodiversity enhancements such as wildflower areas and tree planting. Further information is available in our Green Infrastructure Planning and Design Guide .

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 347 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 11

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy TCL1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy TCL1 - Existing Holiday Parks

It is noted that recreational disturbance has been considered (paragraph 11.4), and that mitigation may be required in line with Policy NAT4 as well as potential nutrient loading with reference to NAT5 (paragraph 11.5). Conserving and enhancing green infrastructure on site would help to ease some recreational disturbance as well as softening any new development into the landscape.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 348 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 11

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy TCL2

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy TCL2 - New Tourist Accommodation

Natural England supports the principle that new tourist accommodation within areas of the Borough designated as National Landscapes will not be permitted. This will ensure that the National Landscape is protected from development which may undermine its special qualities.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 349 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 11

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy TCL3

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy TCL3 - New Tourist Attractions outside of Development Limits and existing tourist areas

The policy considers recreational disturbance on nearby designated sites. Contributions to mitigate impacts will be required in accordance with Policy NAT4. Natural England is supportive of prohibiting such development within the Norfolk Coast National Landscape as this will safeguard the designation.

In Chapter 11 Tourism, Culture and Leisure Planning Policies there could be an additional line in the main body of the policy text that covers environmental issues and encapsulates Nutrient Neutrality, recreational disturbance, access to green infrastructure and landscape.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 350 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 12

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HEC2

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy HEC2 Open space provision for new housing development

The Planning Practice Guidance on Green Infrastructure and the Green Infrastructure Framework helps local planning authorities and developers meet green infrastructure requirements. The Green Infrastructure Framework aims to support local authorities, developers, parks and greenspace managers, and local communities to enhance and create new good quality green infrastructure. Its aim is to enable the development of informed and comprehensive green infrastructure related policy and strategy that is based on the Natural England Green Infrastructure Principles, Standards and data, which can be built on to address local needs and respond to local opportunities (Process Journey for Local Planning Authorities ).

Natural England is supportive of the new thresholds and standards for open space provision, in particular Accessible Natural Green Space per 50 dwellings which has been set out in the policy following the Regulation 18 consultation. It is also important that the quality of on-site green space is considered as well as the quantity in line with the Green Infrastructure Framework. GI Standard 2 (Accessible Greenspace Standards) recommends 'at least 3 hectares of publicly accessible greenspace per 1,000 population and there is no net loss or reduction in capacity of accessible greenspace per 1,000 population at an area-wide scale.'

It is welcomed in the supporting text that accessible on-site natural green space must include dog walking routes and long term management and maintenance. We also welcome the reference to GIRAMS in Paragraph 12.15 and how this will be required in addition to open space. Natural England advises that in addition provisions should also typically include:

• High-quality, informal, semi-natural areas

• Dedicated 'dogs-off-lead' areas

• Signage/information leaflets to householders to promote these areas for recreation

• Dog waste bins

Winterton Dunes National Nature Reserve and the coastal heath habitats at Winterton-Horsey Dunes Special Area of Conservation (SAC) and Great Yarmouth North Denes Special Protection Area (SPA) are under high recreational pressure. This leads to erosion, reduced ecological diversity and unfavourable condition assessments, plus a major disturbance impact on coastal breeding and ground nesting birds. Therefore, more green spaces are needed to take recreational pressure off these sites. There is also a need for large green accessible dog walking friendly spaces to reduce pressure on vulnerable protected habitats in the Borough and this could be developed through the GIRAMS.

Suggested Modifications: It was recommended that quality was also considered referring to the Green Infrastructure Framework.It was recommended that paragraph 12.15 should be expanded to consider additional provision of:

• High-quality, informal, semi-natural areas

• Dedicated 'dogs-off-lead' areas

• Signage/information leaflets to householders to promote these areas for recreation

• Dog waste bins

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 351 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 12

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HEC3

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy HEC3 Protection of open spaces and Green Infrastructure

Natural England notes that the title of this policy now includes Green Infrastructure following our previous comments.

NPPF Paragraph 188 states that: "Plans should distinguish between the hierarchy of international, national and locally designated sites; allocate land with the least environmental or amenity value, where consistent with other policies in this Framework; take a strategic approach to maintaining and enhancing networks of habitats and green infrastructure; and plan for the enhancement of natural capital at a catchment or landscape scale across local authority boundaries".

There are many additional benefits that a strategic approach to Green Infrastructure provision can provide in addition to open space. These include health benefits (NPPF paragraph 8b), improved air and water quality (NPPF paragraph 199), safe and inclusive places (NPPF paragraph 96) and climate change adaptation (NPPF paragraph 164).

Natural England advise that a strategic approach to delivering, maintaining and enhancing green infrastructure in line with the NPPF is outlined in the Plan through policies and we encourage you to incorporate the principles and standards in the Green Infrastructure Framework within your Plan.

This policy could also reference the Norfolk Local Nature Recovery Strategy to ensure that current ecological networks are not compromised and future improvements in habitat connectivity are not prejudiced. Consideration should be given to wider benefits such as carbon capture, flood risk management, enhanced access to nature and the consequent benefits to health from enhanced biodiversity.

As part of the background evidence for this policy, you may wish to include Natural England's Accessible Natural Green Space Standards ANGSt.

Suggested Modifications: It was recommended that the policy references the Norfolk Local Nature Recovery Strategy and that consideration should be given to wider benefits such as carbon capture, flood risk management and enhanced access the nature.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 352 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 12

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HEC5

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy HEC5 Pollution and Hazards in development

Following our previous comments on the Regulation 18 consultation, we welcome that a reference to the Air Pollution Information Service (APIS) to identify background pollution levels and critical levels and loads for designated sites has been included (paragraph 12.34).

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 353 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 12

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HEC6

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy HEC6 Surface and Groundwater Pollution

Natural England supports this new policy where water or waste discharge is in an SSSI impact risk zone. We also support the mitigation measures in the policy including the need for information in a Construction Environmental Management Plan and the use of sustainable drainage systems (SuDS).

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 354 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 14

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CLC1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy CLC1 - Coastal Change Management

Natural England supports the 30m buffer area and that the line of the Coastal Change Management Area is not fixed and has some flexibility around the likelihood of coastal change in the next 100 years. We note that the Environment Agency is due to publish new evidence in the spring 2025 around erosion rates so the zone under threat may change (https://www.gov.uk/guidance/updates- to-national-flood-and-coastal-erosion-risk-information).

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 355 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 14

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CLC2

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy CLC2 - Flood Risk

Natural England supports the use of SuDS to manage surface water disposal. These systems can be used to create wetland habitats for wildlife in an attractive aquatic setting. The CIRIA guidance (susdrain.org) provides useful information about integrating SuDS and biodiversity and we note that this has been referenced in the Design Code (page 341). The maintenance of SuDS should be provided for the lifetime of a project.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 356 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 14

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CLC3

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy CLC3: Foul Drainage

Natural England supports that all new overnight development proposals within a nutrient neutrality catchment zone must be in accordance with Policy NAT5 Nutrient Neutrality.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 357 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 14

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CLC4

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy CLC4: Renewable and Low-Carbon Energy Development

The Policy states that new development will need to be made acceptable in respect of landscape character and the special qualities of nationally and internationally designated conservation sites and their qualifying features, habitats, biodiversity and geodiversity. It is acknowledged that this excludes onshore turbines. There is a potential for loss of agricultural land (please refer to our advice on page 4 and 5). However, the policy has provided a sequential approach by looking first to lower grade agricultural land for solar proposals and also including continued agricultural use and biodiversity improvements. Natural England supports the Policy which is in line with NPPF paragraph 165 a) 'ensuring that adverse impacts are addressed appropriately (including cumulative, landscape and visual impacts)'.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 358 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 14

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CLC5

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy CLC5 - Relocation from Coastal Change Management Areas

Natural England supports that relocated/replacement development due to coastal change would need to demonstrate no net detrimental impact upon the landscape, townscape or biodiversity of the area.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 359 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 15

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy DHE1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy DHE1 - Design

Natural England is supportive of section d) (Public open space, nature and water) which ensures development conserves and enhances biodiversity, geodiversity and landscape features in accordance with Policies NAT1, NAT3, NAT7, the provision of green infrastructure and additional trees on movement routes.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 360 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Natural England is supportive of the policy which accords with the Conservation of Habitats and Species Regulations 2017 (as amended) and the NPPF paragraph 193.

Natural England is also supportive of the reference to the Local Nature Recovery Strategy in designing ecological networks.

Natural England notes the inclusion of references to Sites of Special Scientific Interest and National Nature Reserves, and the clarification of which designated sites need an ecological assessment as highlighted in our previous response to the first Draft Local Plan Consultation.

Natural England supports the additional paragraph in the supporting text (paragraph 16.6), that encourages the use of ecological features such as bat boxes, swift bricks and hedgehog highways into new development.

The mitigation hierarchy (i.e. that development should first seek to avoid, then mitigate or, as a last resort, compensate for significant harm to biodiversity) is referenced in this policy and is explained further in the supporting text, in line with paragraph 193 a) of the NPPF. The Plan should also aim to achieve wider environmental gains, going beyond BNG to include wider natural capital benefits such as improved water and air quality and recreation. Natural England's Environment Benefits from Nature tool can help identify opportunities. This has been developed by Natural England to work alongside the biodiversity metric, mirroring the approach by applying a matrix of scores for different habitats and ecosystem services, which are modified by multipliers reflecting habitat condition, spatial location, delivery risk, and the time taken for new habitats to reach maturity.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 361 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT2

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy NAT2 - Locally Designated Sites

Natural England is supportive of the policy and the reference to the Local Nature Recovery Strategy. While Natural England welcomes the inclusion of the need for a management plan for compensatory habitats, it would be even better if a mechanism for the on-going management of the site was also required to give confidence that the management plan will actually be put into practice.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 362 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT3

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy NAT3 - Biodiversity Net Gain (BNG)

Natural England welcomes the inclusion of BNG of 20% for major development noting that the mandatory requirement set out in the Environment Act 2021 is that developments deliver a minimum of a 10% increase in biodiversity. We are supportive of the reference to ecological networks in the policy as suggested in our previous response to the first draft Local Plan Consultation.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 363 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT4

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy NAT4 - National Site Network designated habitat sites, Ramsar sites, and species impact avoidance and mitigation

Natural England is supportive of the policy which will help to mitigate the impact of recreational disturbance on SPA, SAC and Ramsar sites in the Borough through the measures outlined, and payment to GIRAMS. We note that the method of securing the mitigation through S106 or S11 payments has been stated (paragraph 16.28). We also highlight that the GIRAMS payment is for the in-combination impacts of recreational disturbance only and large developments are likely to require on-site green infrastructure in addition to this to mitigate their impact alone.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 364 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT5

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy NAT5 - Nutrient Neutrality

Natural England supports that the paragraph 16.33 now includes clarification that a HRA will still be required if a development inside the Nutrient Neutrality catchment drains outside of it.

Reference to the calculators and guidance available for applicants to undertake a nutrient budget calculation and develop a mitigation strategy would be useful in paragraph 16.34.

Natural England notes that other pathways in addition to surface water have been considered for non-residential development (paragraph 16.34). Natural England supports the need for a HRA in these instances.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 365 / Respondent: Natural England Gemma Clark

Date Received: 1/31/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT7

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Policy NAT7 - Landscape Character

Natural England supports the policy and suggests that a revised Landscape Character Assessment would be a useful exercise in the future as certain character areas may have changed considerably since the last one was carried out for the borough in 2008.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Date Received: 1/31/2025

Section of the Plan: 0

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Habitats Regulations Assessment

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Habitats Regulations Assessment of the Great Yarmouth New Local Plan Regulation 19 (dated November 2024, Land Use Consultants (LUC)

Your appropriate assessment concludes that your authority is able to ascertain that the plan will not result in adverse effects on the integrity of any European and International Sites. The sites screened in for appropriate assessment are:

• The Broads SAC

• Broadland SPA & Ramsar

• Great Yarmouth North Denes SPA

• Outer Thames Estuary SPA

• Winterton-Horsey Dunes SAC

• Breydon Water SPA & Ramsar

• Greater Wash SPA

• Southern North Sea SAC

• Benacre to Easton Bavents Lagoons SAC

Having considered the assessment, and the measures proposed to mitigate for any adverse effects, it is the advice of Natural England that it is not possible to ascertain that the proposal will not result in adverse effects on the integrity of the sites in question.

Natural England has concerns regarding the Air Quality Assessment which we have outlined below.

Physical damage and loss of habitat

Policies NAT1 and NAT4 will provide protection to designated sites (listed above) from damage and loss of habitat. The requirement for ecological assessment within Policy NAT4 would also identify the presence of functionally linked habitats within or adjacent to a development site.

Policy URB27 Great Yarmouth Racecourse - requires applicants to "protect and enhance the [Great Yarmouth] North Denes SSSI located within the racetrack'' (Great Yarmouth North Denes is also a SPA), and Policy CLC1 Coastal change management - prevents new development (and therefore loss/damage of habitat) within the coastal change management area. Therefore, these policies provide additional mitigation.

Bird Strike

Policy CLC4 requires that "proposals for renewable energy and low carbon schemes and associated ancillary development will need to be made acceptable in relation to the special qualities of nationally and internationally designated conservation sites and their qualifying features, habitats, biodiversity and geodiversity, and proposals for onshore wind will also need to be accompanied by a project level HRA". In addition to NAT1 and NAT4 this will protect designated site features from the impact of bird strike. Natural England is satisfied that the policy will protect designated features at:

• Broadland SPA and Ramsar

• Breydon Water SPA and Ramsar

• Great Yarmouth North Denes SPA

• Outer Thames Estuary SPA

• Greater Wash SPA.

• Benacre to Easton Bavents SPA.

Non-physical disturbance

As above, policies NAT1 and NAT 4 provide protection for designated sites. Policy HEC5 Pollution and hazards in development and Policy HE6 Protection of amenity provides additional safeguards for non-physical disturbance.

Recreation and Urban impacts

GIRAMS is a strategic mitigation strategy identified to mitigate for the effects of recreational disturbance on European Sites arising from the combined growth in Norfolk. Policies NAT1 and NAT4 provide the main protection for designated sites. Policy NAT4 includes specific provision in relation to recreation pressure and aligns with GIRAMS. Larger developments may need to consider the impact of the development alone on European Sites and include on-site green infrastructure to mitigate for recreational disturbance or urban impacts on European Sites, which should be assessed through a project level HRA.

Policy OSS4 HEC2 provides additional safeguards.

Water Quality and Quantity

In terms of direct pollution, designated sites are protected by NAT1, NAT4, HEC5 and HEC6.

Abstraction has the potential to impact the Broads SAC, Broadland SPA and Ramsar directly, however there are existing measures in the regulatory framework of which water companies operate. This coupled with provision in policies NAT1 and NAT4 is considered sufficient to reduce the minimal risk to functionally linked habitats from abstraction.

Policy OSS4 Infrastructure provision and Policy CLC8 Water conservation will reduce demand and provide a mechanism for funding infrastructure improvements.

In our previous response to the first draft Local Plan Consultation we stated that it was not possible to rule out adverse effects on integrity to the Broads SAC, and Broadland SPA and Ramsar as Suffolk Water's final 2024 Water Resources Management Plan (WRMP) and its HRA have not yet been published. We requested confirmation that the final 2024 WRMP HRA concluded no adverse effects on integrity of these sites. The 2024 WRMP was published alongside its HRA in October 2024. The development permitted by Local Plan policies does not exceed what has been planned for in the WRMP. The HRA for the WRMP concludes that there will be no adverse effects on integrity, based on the implementation of mitigation (such as pollution control, timing of works etc). Natural England are satisfied that there will be no adverse effect on integrity on designated sites as a result of abstraction.

Wastewater treatment and discharge is a risk to the Outer Thames Estuary SPA, due to mains wastewater treatment that discharges to the sea, and at the Broads SAC, where standalone wastewater treatment could increase nitrogen or phosphorus loads within the Broads Nutrient Neutrality catchment. Policy OSS4, Policy CLC8, CLC3, HEC6 and Policy NAT5 Nutrients provides policy safeguards no ensure no adverse effects on the integrity of designated sites or their functionally linked habitats.

Air Quality

In our previous response to the HRA we highlighted that it had not been possible to rule out adverse effects on integrity to the following sites in relation to air quality:

• The Broads Special Area of Conservation (SAC)

• Broadland Special Protection Area (SPA) and Ramsar

• Great Yarmouth North Denes SPA

• Outer Thames Estuary SPA

• Breydon Water SPA and Ramsar

• Greater Wash SPA

• Benacre to Easton Bavents SPA.

A Local Plan Air Quality Inputs Habitats Air Quality Assessment, (November 2024, Bureau Veritas) has been included as part of the evidence base for the Local Plan Regulation 19 document and supports the HRA.

There is a 3-year average modelled for ammonia for 2019 to 2021 (page 11) and baseline modelling for traffic flows from 2023-2024. Meteorological data input to the dispersion model is based on data from 2023 (paragraph 4.18). Natural England advise that at least 3 years (and ideally 5 years) of meteorological data from a local representative meteorological station should be used to ensure an assessment is robust.

The Assessment has concluded that for impacts of the Local Plan alone, annual mean ammonia (NH3) concentrations, nitrogen deposition and acid deposition are predicted to be negligible at all identified receptors, except for the transect Broads_1. We advise that further assessment by an ecologist is undertaken at this transect, to identify locations of potentially sensitive habitats, and also to confirm whether these align with areas predicted to experience an increase in pollutant concentrations.

The impacts of the Local Plan in-combination with other plans and projects on NH3 annual concentration are predicted to represent a process contribution of more than 1% of the critical level at all locations. Nitrogen deposition rates are also predicted to represent more than 1% of the critical level at all locations except for Broadland_1 and acid deposition rates are predicted to represent more than 1% of the critical level at all locations, except for Broadland_1 and Breydon Water_1.

Natural England advises that where modelling shows that a process contribution of 1% of critical levels and / or load is exceeded at European sites, either alone or in-combination with other plans and projects, that a likely significant effect cannot be ruled out.

There are several other issues with the Air Quality Assessment that need to be resolved before we can provide detailed advice. We recommend that the consultants take account of Natural England's published guidance Natural England's approach to advising competent authorities on the assessment of road traffic emissions under the Habitats Regulations - NEA001 and address these issues accordingly.

The following are examples of some of the fundamental issues, we caveat that it will not be limited to these examples only:

A likely significant effect (LSE) on Outer Thames Estuary SPA has been ruled out as the bird features of the SPA are not sensitive to changes in air quality. However, whilst the Air Pollution Information System states the birds are not sensitive to Nitrogen Oxides (Nox) or NH3, there is an assigned critical load for nitrogen to some of the bird interest features, which is because of the habitat they rely on. The LSE test is a high level test with additional information being taken forward to the appropriate assessment stage. The appropriate assessment should consider site specific issues that provide evidence that there would not be an AEOI. We would expect this assessment to consider impacts of the habitats and the form and function it provides to the bird species and whether air quality impacts would affect bird species and distribution on the site that could be an AEOI. There are additional interest features of SSSIs that are also susceptible to air pollution that have not been assessed for the Plan. We note that this assessment is in addition to assessment of European Site features in the HRA.

For other sites considered at appropriate assessment, the HRA rules out a LSE as nitrogen and NOx backgrounds will be lower in the future (as a result of cleaner vehicles etc) (paragraph 3.4). This does not take account of the "restore" objectives of the designated sites and that additional process contributions will "retard" (hold back) this objective. If it retards less than 1 year that is acceptable but there is currently no discussion of retardation in the assessment. This is covered in NEA001.

Some other sites have been ruled out as having an AEOI at appropriate assessment because "they are inundated" with water without any further detail. This is not taking into account specific site considerations as to the areas inundated and whether these overlap with areas where the 1% screening threshold is exceeded. It is unlikely that these sites are totally inundated up to the edge of the road so we would expect the appropriate assessment to consider areas that are not fully inundated where the threshold is exceeded.

Natural England can provide detailed comments on an amended version once these issues have been resolved. With the information provided, we cannot ascertain that the proposal will not result in adverse effects on the integrity of the sites in question. This is a separate issue to the that of the plan being sound as a whole and therefore we would be happy to advise on any revisions to the Air Quality Assessment and the Air Quality information in the HRA.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP324-369 - Natural England (PDF, 306 KB)(opens new window)

Rep ID: 370 / Respondent: Suffolk County Council Georgia Teague

Date Received: 1/31/2025

Section of the Plan: 1

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:General

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Thank you for consulting Suffolk County Council (SCC) on the Great Yarmouth Local Plan at Submission stage.

It is noted that the Consultation Statement does not indicate whether SCC has been consulted at previous stages of this local plan.

Economic Strategy

SCC would suggest that the following points from the Norfolk and Suffolk Economic Strategy1 be considered as part of this local plan:

• Alignment with key sectors and growth areas - clean energy being the most prominent, visitor economy being another.

• Innovation support - encouraging innovation hubs and business support facilities.

• Clean energy collaboration - The GENERATE partnership is instrumental in this a partnership between Great Yarmouth, East Suffolk, Norfolk and Suffolk County Councils. The local plan should support complementary infrastructure and policies that capitalises on the areas strength in clean energy.

• Access to Skills development and opportunities: Supports improvements in connectivity to access skills development and employment hubs.

Transport

SCC believes there to be a minimal cross-boundary impact on highways.

The area of Suffolk that is north of Lowestoft is particularly rural and unlikely to have any significant traffic issues made worse by any development located near to our borders.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP370 - Suffolk County Council (PDF, 113 KB)(opens new window)

Rep ID: 371 / Respondent: Lanpro Services Limited on behalf of Potters Leisure Limited John

Date Received: 1/31/2025

Section of the Plan: 11

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy TCL1

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Complies with Duty to Co-operate

Reasons: The draft policy permits new, upgraded or expanded tourist accommodation and ancillary uses (such as food and drink uses or small convenience shops) within existing holiday parks (as defined on the Policies Map). The draft policy requires such development to be of a high standard of design in accordance with Policy DHE1, relevant Borough wide design requirements and DDR5 of the Design Code, and will: support year-round use where possible; be of a proportionate scale to the existing holiday park; ensure ancillary retail uses are of a scale to meeting the needs of tourists and no more than 200sqm in net floorspace; ensure traffic volume does not have a significant adverse impact on traffic and highway safety; and encourage use of active travel and public transport. The draft Policy states that new hotel accommodation will be required to pass the sequential test in accordance with national town centre use policy and Policy RTC2. Occupancy restrictions will also apply to ensure accommodation is not used for permanent residential occupancy.

Notably, the draft Policy states that "Expansions to existing holiday parks, that are developed over the plan period, and are located outside of, but adjacent to, existing holiday parks, will be treated as being an 'existing holiday park' for the purposes of this Policy."

The draft Policy also states the existing tourist uses within existing holiday park will be protected.

Potters Response: Likewise to the Regulation 18 representation, the Policy support for new, upgraded or expanded tourist accommodation and ancillary uses within existing holiday parks is welcomed, along with being of a high standard of design and encouragement of sustainable transport use.

However, whilst it is agreed that development should be of a "proportionate scale" to the existing holiday park, there is no definition as to what proportionate means and therefore is considered to be subjective. There is therefore a risk that this is applied in a manner that arbitrarily constrain proposals. Potters would therefore like to see this policy applied with flexibility.

In respect of traffic and highway safety, it is welcomed that new development should not have a significant adverse impact. As a tourist attraction, the objective is to attract visitors; the allowance for a degree of impact is welcomed.

As Policy TCL1 relates to existing holiday parks, the application of the sequential test is not considered to wholly align with paragraph 91 of National Planning Policy Framework (NPPF) (20232) and should be removed from this policy.

As stated in the Regulation 18 representation, Potters strongly believe that the existing holiday park allocation on Potters Resort needs to be extended to the south of the resort. That being said, the support for the expansion to existing holiday parks, located outside of, but adjacent to existing holiday parks to be treated as being an 'existing holiday park' for the purpose of the Policy is strongly welcomed. Ongoing re-investment and carefully considered expansion is key to ensuring that the tourist industry continues to attract visitors and provide businesses resilience and stability in a fragile economy.

Policy support for a year-round use is also welcomed, as is the supporting text at paragraph 11.1 which states that "The policy is flexible and encourages ancillary uses suitable to cater for a strong local tourist industry that operates sustainably on a year-round basis". However, it is strongly contended that this narrative is wholly contradictory to draft Policy NAT9 (Dark Skies) which sets out a number of restrictive requirements for lighting. Whilst it is acknowledged that the Borough comprises areas of the Broads network and other important landscapes, and the high risk of increased disturbance at nearby National Site Network habitat sites as noted in the supporting text at paragraph 11.4, this is a blanket policy over a wide area. This policy will be discussed in greater detail below, however, it is not considered to be appropriate in the context of draft Policy TCL1.

To summarise, Potters generally welcome the majority of draft Policy TCL1, notably the continued support for new, upgraded or expanded tourist accommodation and the application of the policy to the expansion of existing holiday parks, located outside of, but adjacent to existing holiday parks. There are, however, a number of elements which Potter strongly object to, including:

• Requirements to be of a proportionate scale due to the potential to arbitrarily constrain proposals;

• Application of the sequential test does not wholly align to paragraph 91 of NPPF (2023);

• Basis of dark sky restrictions contradicting the purpose of the policy to support existing holiday parks.

On this basis, the Policy is considered to be 'unsound' in the context on paragraph 35 of NPPF (2023) due to not being justifiable nor consistent with national policy.

Suggested Modifications: View full representation

Request to be heard?: Yes

Reason for Request to be heard:View full representation

Attachments: REP371-377 - Potters Leisure Limited (PDF, 2 MB)(opens new window)

Rep ID: 372 / Respondent: Lanpro Services Limited on behalf of Potters Leisure Limited John

Date Received: 1/31/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT9

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Complies with Duty to Co-operate

Reasons: Draft Policy NAT9 - Dark Skies

Draft Policy NAT9 states that all proposals are required to address light spillage and avoid all unnecessary forms of artificial outdoor lighting and sets a number of restrictions, including, inter alia: appropriateness; beam angle direction; correlated colour temperature; and no significant adverse effects of the lighting individually or cumulatively on the character of the area, residential amenity, safety of vehicular users/pedestrians or the diurnal/seasonal rhythms of the Borough's biodiversity assets.

Specific to development in Dark Sky Zone 2 in which Potters Resort is situated, the following, in summary and inter alia, are to apply: planning permission will only be granted subject to conditions to secure a lighting strategy and a restrictive condition shall be imposed to prevent the installation of additional permanent lighting post-occupation without further planning permission; minimal road and footway lighting only where appropriate to the surrounding context; sports lighting only where there is demonstratable need and provides public benefits in favour of the scheme; and no digital advert displays will be permitted. The draft Policy states that a full lighting strategy scheme will be required for proposals in Dark Zone 2 and this should demonstrate that there will be no significant adverse effects on the visibility of the night sky, or its immediate dark landscapes.

Potters Response: Likewise to the Regulation 18 Representation, Potters strongly object to this wholly restrictive draft Policy being applied to the long-established Potters Resort. Whilst Potters acknowledge detrimental impact of light pollution on the environment, human health, and night sky as an important matter, the Council have applied a blanket policy over a significant area, with no flexibility to existing holiday parks, despite support for a year-round use.

Potters is the largest year-round, entertainment led tourism destination in the area with festive and themed events during the spanning months. The resort operates outdoor stages, floodlit sports activities, all requiring a vibrant, well-lit environment. The World Bowls is a prominent event during January, which Potters has hosted since 1999. This too requires extensive lighting and broadcasting set-ups.

Lighting is also of paramount importance to the health and safety requirements of a year-round holiday park. At Potters Resort, out of season guests are predominantly a mature audience with sometimes limited mobility. Appropriate lighting is therefore an absolute essential to ensure guests can travel around the resort with a feeling of safety, ease and confidence. Failure to provide satisfactory lighting could lead to falls and accidents, where guests' holiday experience is tarnished with a trip to James Paget University Hospital, and ultimately impact the functionality of the business.

Potters very strongly urge that the Council review the boundaries of the Dark Sky Zones to omit the Borough's critical tourist hot spots from such restrictions. Failure to do so will result in a detrimental impact on the prosperity and future of such businesses, and ultimately the local economy of the Borough, in contradiction to Policy TCL1 and paragraph 35 and 36 on NPPF (2023).

Greater consideration to allow appropriate levels of lighting must be allowed for existing and well-established tourism resorts to allow them to function, especially out-of-season during the winter months. We kindly request an amendment to the wording of the policy to clarify that for such restrictions apply only to new proposals on undeveloped sites. This is of critical importance and should not be ignored.

Suggested Modifications: View full representation

Request to be heard?: Yes

Reason for Request to be heard:View full representation

Attachments: REP371-377 - Potters Leisure Limited (PDF, 2 MB)(opens new window)

Rep ID: 373 / Respondent: Lanpro Services Limited on behalf of Potters Leisure Limited John

Date Received: 1/31/2025

Section of the Plan: 6

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Polcy HOP2

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Complies with Duty to Co-operate

Reasons: Draft Policy HOP2 - Land at Coast Road, Hopton

Land at Coast Road, Hopton is proposed to be allocated for approximately 40 dwellings and 26 sheltered housing / housing with an element of care. The draft Policy indicates that a number of requirements should be met including, inter alia, a density of approximately 25 dwellings per hectare; accordance with Boroughwide design requirements and DDR1 of the Design Code; access improvements; relocation of the car parking within a safe walking distance of Potters Resort and is provided to a satisfactory level for future residents, staff and visitors of Potters Resort; 0.41ha open space comprising play space, informal amenity space and accessible greenspace; and offsite BNG in accordance with Policy NAT3.

Supporting text at paragraph 6.104 explains that the Site was originally allocated for mixed use development in the Local Plan Part 2 (2021) for 40 homes, staff accommodation and continued business use for the adjacent Potters Resort. However, the landowner (Potters) identified there is no longer an operational need for staff accommodation or business use. Based on the capacity for primary school children, it states that it would not be appropriate to increase the number of market housing on Site. It also states that the location is well placed for additional elderly/specialist accommodation due to the range of services and facilities Hopton-on-Sea offers, along with a bus stop 60m north of the Site.

Potters Response: Following on from the Regulation 18 Representation, Potters strongly support the change in policy and welcome collaboratively working with the Council to bring the Site forward for development in the future. However, there are a number of matters to raise.

Whilst we acknowledged in the Regulation 18 Representation that increasing the number of residential dwellings may not be suitable, there could be scope to address the low capacity of school spaces in the locality through developer contributions and the situation may change. This would also be consistent with paragraph 123 of NPPF (2023) which seeks to promote an effective use of land in meeting the need for homes, and the Government's drive to increase the supply of housing as reflected in the December 2024 NPPF.

Whilst supporting paragraph 6.109 makes reference to the Site being small, meaning compensatory planting cannot be practically achieved on Site, we do not consider the promotion of offsite biodiversity net gain to accord with the regulations. The biodiversity gain hierarchy must be considered when deciding whether biodiversity objectives have been met and when determining whether to approve an application. As set out at Schedule 37A of The Town and Country Planning (Development Management Procedure) (England) Order 2015 (as amended), the creation/enhancement of green infrastructure and soft landscaping within the proposed development boundary is the preferred option and needs to be exhausted prior to moving to off-site solutions. Furthermore, Draft Policy NAT3 requires all major development to deliver at least a 20% measurable biodiversity net gain which we do not consider to be acceptable and comment on in due course.

To provide further clarity in respect of the car park, it is the intention to locate this to the south of the allocation.

It is acknowledged that the Council are consulting on the Community Infrastructure Levy (CIL) Draft Charging Schedule including a nil CIL rate for sheltered / extra care housing. Whilst a separate representation is being made, we welcome this in the context of Draft Policy HOP2.

Suggested Modifications: View full representation

Request to be heard?: Yes

Reason for Request to be heard:View full representation

Attachments: REP371-377 - Potters Leisure Limited (PDF, 2 MB)(opens new window)

Rep ID: 374 / Respondent: Lanpro Services Limited on behalf of Potters Leisure Limited John

Date Received: 1/31/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT3

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Complies with Duty to Co-operate

Reasons: Draft Policy NAT3 - Biodiversity Net Gain

Draft Policy NAT3 requires all major development proposals to deliver at least a 20% measurable biodiversity net gain attributable to the development. An exception to 20% BNG includes brownfield sites, and areas within the Development Limits of Great Yarmouth, Gorleston-on-Sea, Bradwell and Caister-on-Sea. The Policy also notes that BNG should be provided on-site wherever possible and where off-site measures will be considered, including the BNG hierarchy, along with management responsibilities.

Potters Response: Whilst Potters do not disagree that development should provide a net gain in biodiversity, this does not follow the latest Planning Practice Guidance which states the following:

"Plan-makers should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, either on an area-wide basis or for specific allocations for development, unless justified. To justify such policies, there will need to be evidence including as to local need for a higher percentage, local opportunities for a higher percentage and any impacts on viability for development. Consideration will also need to be given to how the policy will be implemented." (Paragraph: 006 Reference ID: 74-006-20240214)

Paragraphs 16.12. - 16.15 of the supporting text explain the Council's justification for this, including that less than 8.2% of land in Norfolk is specifically protected for wildlife through a Sites of Special Scientific Interest designation; the highest priority scoring in the UK Tree Equity Score. We do not consider this to be a sufficient justification.

Suggested Modifications: View full representation

Request to be heard?: Yes

Reason for Request to be heard:View full representation

Attachments: REP371-377 - Potters Leisure Limited (PDF, 2 MB)(opens new window)

Rep ID: 375 / Respondent: Lanpro Services Limited on behalf of Potters Leisure Limited John

Date Received: 1/31/2025

Section of the Plan: 14

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CLC1

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Complies with Duty to Co-operate

Reasons: Draft Policy CLC1 - Coastal Change Management

Draft Policy CLC1 notes that other development at risk between 2055 and the delineated in-land edge of the Coastal Change Management Area (CCMA) will only be permitted subject to a number of requirements. Development should demonstrate that it isa compatible form of development in regard to any anticipated potential increase in erosion and flood risk, due to coastal change during the planned life of the development having regard to the indicative erosion zones identified in the Shoreline Management Plan or the National Coastal Erosion Risk Map; will provide a wider benefit to the local coastal community and/or economy; and would not impact the stability of the coastline, the rate of shoreline change, or increase demands for investment in coastal defences.

The draft Policy states that all planning applications for development within 30 metres inland beyond the CCMA must be accompanied by a Coastal Erosion Vulnerability Assessment which demonstrates that the development will not result in an increased risk to life or property.

Potters Response: It is acknowledged that Potters Resort are directly east of the CCMA. Given the importance of the coastline and the need to preserve it as much as possible, Potters appreciate that development must not result in any degradation of it and support this policy. However, further detail needs to be added as to how the 30m is applied. In our view, it should be clarified that the 30m figure relates to build form, as opposed to ancillary matters such as landscaping areas. We consider that this would be more practically be applied to the proposed development.

Suggested Modifications: View full representation

Request to be heard?: Yes

Reason for Request to be heard:View full representation

Attachments: REP371-377 - Potters Leisure Limited (PDF, 2 MB)(opens new window)

Rep ID: 376 / Respondent: Lanpro Services Limited on behalf of Potters Leisure Limited John

Date Received: 1/31/2025

Section of the Plan: 2

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Vision and Objectives

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Complies with Duty to Co-operate

Reasons: Objectives

Objective 4 of the draft Local Plan is as follows:

"To improve and grow the year-round tourist offer of the Borough, including the enhancement of Great Yarmouth and Gorleston seafronts."

Potters Response: A key element of Potters Resort's business success is the ability to enjoy a 100% year-round occupancy, even in the dark winter months on the cold east coast. The objective to improve the year-round tourist offer is welcomed on the basis that it would enhance the offering to Registered Office Registered Number 6593948

6 Central Avenue, St. Andrew's Business Park, VAT Number 932 990 302

Norwich, NR7 0HR

visitors at Potters. However, policy mechanisms must be in place to enable this. For instance, appropriate lighting provision during the shorter days - we comment on this point in due course.

Suggested Modifications: View full representation

Request to be heard?: Yes

Reason for Request to be heard:View full representation

Attachments: REP371-377 - Potters Leisure Limited (PDF, 2 MB)(opens new window)

Rep ID: 377 / Respondent: Lanpro Services Limited on behalf of Potters Leisure Limited John

Date Received: 1/31/2025

Section of the Plan: 1

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:General

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Complies with Duty to Co-operate

Reasons: Key Issues and Matters

Amongst others, one of the key opportunities stated is the Borough's strong tourism industry. The draft Local Plan stipulates that as of 2019, the value of the Borough's tourism industry was estimated at £648 million, supporting 9,369 jobs.

Potters Response: Potters strongly agree that the tourism industry is a key opportunity for the Borough, and provides a valuable contribution to the local economy. Potter's plays a critical role in this being the largest single site tourism employer in the Borough with 600 employees. Potters represents the last of the original pioneering independently owned holiday camps and is still owned and run by the original family 104 years on, with approximately 250,000 'bed nights1' a year. With numerous local and national awards, the Resort puts Great Yarmouth on the map and should continue to be supported in its committed, forward-thinking venture.

Suggested Modifications: View full representation

Request to be heard?: Yes

Reason for Request to be heard:View full representation

Attachments: REP371-377 - Potters Leisure Limited (PDF, 2 MB)(opens new window)

Rep ID: 378 / Respondent: Planning Issues on behalf of Churchill Living and McCarthy and Stone

Date Received: 1/31/2025

Section of the Plan: 7

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HOU5

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Paragraph 1 of the PPG Housing for Older and Disabled people states:

"The need to provide housing for older people is critical. People are living longer lives and the proportion of older people in the population is increasing, offering older people, a better choice of accommodation to suit their changing needs can help them live independently for longer, feel more connected to their communities and help reduce costs to the social and health systems. Therefore, an understanding of how the ageing population affects housing needs is something to be considered from the early stages of plan-making through to decision-taking".

Paragraph 001 Reference ID: 63-001-20190626

The delivery of a suitable level of specialist older persons' housing will be a substantial undertaking over the Local Plan period and unless action is urgently taken the Council will struggle to address this need. The inclusion of a dedicated policy which is supportive of the need to deliver specialist older persons' housing at suitable locations is commendable and supported accordingly.

Notwithstanding the above, the need for older persons housing could be expressed within Draft Policy HOU5, in line with the conclusions of the Norfolk Study of Older Persons Housing ( published in November 2021) produced by Three Dragons and

Opinion Research Services. This report identifies at paragraph 1.22:

"Across the whole of Norfolk in 2020, there is unmet need for 2,809 units of extra care housing and 3,203 units of sheltered housing. By 2041, these figures will have nsen to 5,730 and 9,644 respectively "

This is a seismic shift in not only the population of older people, but also the housing requirement needed to house th is population. Subsequently, the report further highlights that demand for Great Yarmouth equates to 596 extra care units and 752 sheltered units by 2041 to meet the expected demand.

Furthermore, in a report by Ridgeway Associates Consulting Ltd (published March 2023), it is stated that there is a currently supply of 1,088 sheltered housing units and 64 Extra Care Housing units in Great Yarmouth BC It is also acknowledged there will be a need for an additional 1,188 sheltered housing units and 755 units of Extra Care Housing by 2041 Both reports therefore provide unequivocal evidence that there is a st rong need for specialist accommodation for the elderly within the Great Yarmouth borough.

Suggested Modifications: Suggested that Policy HOU5 is amended to: "The provision of specialist accommodation that is suitable for the elderly, includ ing sheltered housing, supported housing, extra care housing and residential/nursing care homes will be encouraged. Provision will be made for at least an additional 1,188 units of sheltered housing and 755 units of extra care housing by 2041"

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP378-379 - Churchill Living and McCarthy Stone (PDF, 508 KB)(opens new window)

Rep ID: 379 / Respondent: Planning Issues on behalf of Churchill Living and McCarthy and Stone

Date Received: 1/31/2025

Section of the Plan: 7

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HOU1

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: Draft Policy HOUl: Affordable Housing requires all sites with a capacity of 10 or more units to provide 25% affordable housing.

The policy highlights "where a site qualifies for affordable housing, the percentage sought will be 25% unless policies included within this plan prescribe otherwise"

We note within the Evidence Base supporting the emerging Local Plan that the Council have commissioned HDH Planning & Development Ltd to undertake a Plan The Viabil ity Assessment has tested sheltered and Extra care sectors separately, which is welcomed. Paragraph 10.81 sets out the conclusions made by HDH Planning and Development:

"Based on this analysis, specialist older peoples housing is unlikely to be able to bear affordable housing. It follows that such development does not have capacity to bear CIL."

As a result of these conclusions, Draft Policy HOUS: Housing for Older People states:

"The development of sheltered and extra care dwellings will not be required to make provision for affordable housing, as required by Policy HOU1."

This is a welcome addition to the draft policy wording and accurately reflects the findings of the Viability Assessment, to which many other Council usually disregard.

On that basis, this is a commendable step in supporting the delivery of older persons housing in the district.

Thank you for the opportunity for comment.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP378-379 - Churchill Living and McCarthy Stone (PDF, 508 KB)(opens new window)

Rep ID: 380 / Respondent: Marrons on behalf of Inside Land Group Limited

Date Received: 1/31/2025

Section of the Plan: 1

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:General

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Does not comply with Duty to Co-operate

Reasons: As the LPA will be aware, on 12th December 2024 the Government published a new National Planning Policy Framework ("NPPF") alongside attendant changes to the Standard Method for calculating local housing need ("LHN").

The NPPF contains transitional arrangements at Annex 1. Paragraph 234 stipulates that for the purposes of preparing local plans, the policies in the NPPF will apply from 12th March 2025, other than where a specific number of situations apply as set out in limbs a. - c. of that paragraph.

Limb a. states that the Plan must reach Regulation 19 (pre-submission stage) on or before 12th March 2025 and its draft housing requirement meets at least 80% of local housing need.

The current Regulation 19 consultation documents were published on 6th December 2024. The emerging housing requirement in draft Policy OSS1 (Housing Growth and Location) is 380 dwellings per annum ("dpa"), which is 72.3% of the most recent LHN for the Borough, which stands at 525 dpa. As such, it is clear the Plan cannot benefit from the transitional arrangements under paragraph 234 a.

That said, Limb b. of paragraph 234 sets out that December 2023 version of the NPPF will apply in situations where the Plan has been submitted for examination under Regulation 22 on or before 12th March 2025. In short, to benefit from transitional provisions, the Plan must be submitted under Regulation 22 on or before that date, as simply publishing the Regulation 19 consultation is insufficient to engage transitional arrangements, given the greater than 80% differential between the emerging housing requirement and the LHN. We understand that the LPA intends to submit the Plan for examination prior to the March deadline thereby benefiting from paragraph 234b.

Given the forgoing, we have based our representations upon the soundness of the Plan upon the NPPF 2023 and the associated Planning Practice Guidance ("PPG") on the assumption that the Plan will be submitted for examination on or before 12th March 2025. Should this not be the case, the NPPF 2024 will apply, and the Plan will be plainly unsound, as it would not make provision for the minimum amount of housing required.

Despite the above, we draw the LPA's attention to paragraph 78 c) of the NPPF 2024 which states that, for the purposes of decision-making, the LPA will be required to apply a 20% buffer when calculating its five year housing land supply where it has adopted a Plan within the last five years examined against a previous version of the NPPF and whose annual average housing requirement is 80% or less of the most up-to-date LHN. As such, whilst paragraph 78 c) applies to decision-taking only, the LPA should consider whether adoption a Plan with housing requirement less than 80% of the LHN is prudent and consistent with its desire to achieve Plan-led growth.

We also draw the LPA's attention to paragraph 236 of the NPPF, which states that where local plans are progressed under paragraph 234b, the LPA will be expected to commence work on a new local plan under the revised plan-making system, in order to address the shortfall in housing need. There is no draft policy within the Plan which commits the LPA to such a review upon adoption and it is essential for the Plan's soundness in terms of consistency with national policy that such an early review mechanism is introduced.

Finally, in order to engage the transitional arrangements within the NPPF, the Council will be required to submit the Plan for examination by 12th March 2025. On the basis the Regulation 19 consultation will close by 31st January 2025, the Council will only have a very short time to process and consider the representations received and we are concerned that the rushed timescales to engage transitional arrangements will mean that the LPA will not pay proper regard to the consultation responses received.

Suggested Modifications: Change(s) Requested:

Despite the clear advice of the NPPF (paragraph 234b), the Plan does not contain a strategic policy requiring an immediate review upon adoption to address the shortfall in housing need against the LHN. To remedy this matter, a policy is required within the Plan which sets out a clear commitment to, as well the scope and timing of an immediate Plan review. For effectiveness, such a policy should be clear on the consequences for not progressing the review in a timely fashion and require that housing applications are determined in accordance with the presumption in favour of sustainable development should the timescales for submission for the Plan review not be met.

Vision s Objectives

Request to be heard?: Yes

Reason for Request to be heard:Given our client's fundamental objections to the Plan, we request participation in the hearing sessions as part of the forthcoming Examination in Public (EiP).

Attachments: REP380-384 - Inside Land Group CO Marrons (PDF, 283 KB)(opens new window)

Rep ID: 381 / Respondent: Marrons on behalf of Inside Land Group Limited

Date Received: 1/31/2025

Section of the Plan: 2

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Vision and Objectives

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Does not comply with Duty to Co-operate

Reasons: Comments:

Paragraph 1.10 of the Plan identifies the key issues and opportunities to be addressed. Amongst these are high unemployment rates and low earnings, with the number of jobs in the Borough stagnant since 2015 and unemployment higher than the national and regional average; high levels of multiple deprivation; and significant need for affordable homes and specialist accommodation for the elderly.

The Plan Vision indicates that the health and wellbeing of the population will be enhanced with sufficient, high-quality affordable housing available to meet all needs, as well as benefiting residents through further employment opportunities and earning potential.

For the reasons set out below, in terms of the overall scale and distribution of new homes, the Plan does not respond to the Vision nor to the challenges identified at paragraph 1.10 of the supporting text. The Plan's housing requirement does not make sufficient provision to meet even a fraction of objectively assessed affordable housing need.

In relation to the Objectives, we note that Objective 1 and Objective 8 link to the economic land and housing requirement identified later in the Plan. It is not appropriate for the Vision and Objectives to "pre- determine" development land requirements, which need to be objectively assessed. These two objectives should be re-drafted accordingly.

Suggested Modifications: Changes requested:

The Plan does not address these challenges. Both economic and housing growth will be delivered at the very minimum level possible, barring a small 5% uplift on the LHN. This is not an approach that will address the Vision and Spatial Objectives of the Plan.

Request to be heard?: Yes

Reason for Request to be heard:Given our client's fundamental objections to the Plan, we request participation in the hearing sessions as part of the forthcoming Examination in Public (EiP).

Attachments: REP380-384 - Inside Land Group CO Marrons (PDF, 283 KB)(opens new window)

Rep ID: 382 / Respondent: Marrons on behalf of Inside Land Group Limited

Date Received: 1/31/2025

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy OSS1

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Does not comply with Duty to Co-operate

Reasons: Draft Policy OSS1 - Housing Growth (Amount) Comments:

Draft Policy OSS1 sets a housing requirement for the Borough at 6,460 dwellings from 2024 to 2041 equating to an annual average of 380 dpa. The housing requirement has been calculated using the current Standard Method which equates to 353 dpa, but an uplift of approximately 5% has been applied resulting in 380 dpa, ostensibly due to previous levels of housing delivery and the requirements of previous plans. Otherwise, the housing requirement is analogous to the Standard Method.

The PPG is clear that the Standard Method identifies the minimum number of homes to be planned for. It does not produce a housing requirement.1 There are a variety of factors that may dictate the eventual housing requirement should be higher than indicated by the Standard Method. These include growth strategies for the area, strategic infrastructure improvements and meeting unmet need from neighbouring authorities.2 In addition, the PPG requires that total affordable housing need can then be considered in the context of its likely delivery as a proportion of mixed market and affordable housing developments and that an increase in the total housing requirement included in the plan may need to be considered where it could help deliver the required number of affordable homes.3 We consider these matters in further detail below.

Affordable Housing:

No Local Housing Needs Assessment ("LHNA") has been produced to reflect the changes to the base year of the Plan. The only available LHNA by Opinion Research Services (ORS) dates from May 2022 and considers the period 2021 to 2041. This evidence is almost 3 years old and unlikely to form a robust basis for housing needs assessment. Notwithstanding this, for Great Yarmouth Borough alone, the LHNA estimates an affordable housing need of 111 dpa. Projected across a shorter Plan period, this rises to 130 dpa meaning that the annual affordable housing need estimated within the most recent LHNA equates to 34% of the housing requirement (380 dpa).

On the basis that draft Policy HOU1 (affordable housing) seeks 25% affordable of all qualifying sites (unless a lower percentage is expressly stipulated within the Plan), it is clear that the Plan's housing requirement will not deliver the amount of affordable housing needed. When one considers that a significant portion of the Plan's housing supply derives from previously developed land which have bespoke allocation policies allowing as little as 10% affordable housing, the deficit will become even more pronounced.

On the basis that the emerging housing requirement is similar to the one contained in the current Core Strategy (Local Plan Part 1 - 2015), we have considered affordable housing completions in Great

1 Paragraph: 002 Reference ID: 2a-002-20190220

2 Paragraph: 010 Reference ID: 2a-010-20201216

3 Paragraph: 024 Reference ID: 2a-024-20190220

Yarmouth across a 10 year average, using the Government's live tables. These indicate that over the last 10 years, the Borough has seen approximately 46 affordable dwellings completed per annum. As this is a level manifestly below the reported need, it is very unlikely that the housing requirement contained within draft Policy OSS1 will enable sufficient affordable housing to be built.

There is no acknowledgement within the Plan or its evidence base of the link between the housing requirement and meeting total affordable housing need and thus, the PPG has not been appropriately applied. There is no indication of why the housing requirement could not be uplifted to address more of the affordable need, despite the fact the LPA has clearly deemed this to be necessary, as part of the rationale for the 5% uplift of the LHN is to secure the delivery of more affordable homes. However, the 5% uplift is arbitrary, not evidence-led and does not bear any relationship to the quantum of unmet affordable housing need, which is substantial.

Flexibility C Contingency:

The Plan's housing supply consists of 6,638 dwellings, which equates to a 3% buffer on the minimum amount of housing expected over the Plan period. Whilst it is noted that this figure does not include windfall, this is an inherently uncertain source of supply and should this falter during the Plan period there is very little headroom Plan to absorb any shortfalls. Plans should be positively prepared and capable of responding to changing circumstances. The Council should introduce further sources of housing supply to ensure the sufficient level of flexibility and contingency.

Sustainability Appraisal:

The Council has tested a higher overall provision figure (33% over and above the housing "target") and appraised this against the Sustainability Appraisal ("SA) Framework. The scoring of this option (Option OSS1h) does not appear to take into account the obvious positive effects of delivering more affordable housing (aligned with SA Objective 1 to reduce multiple deprivation). As the SA effects in terms of overall housing provision have not been cross tested against any spatial distribution option, the outcomes are largely uncertain. For example, it is not necessarily the case that this option will mean growth areas with poorer accessibility (SA6) - that is a question for growth distribution rather than the overall scale. Overall, this option has not been tested robustly or in a similar level of detail to other options and should be revisited considering our wider comments about the housing requirement set out above.

Housing Land Supply:

The Council has included a housing trajectory at Appendix 8. This shows that the total supply of homes over the Plan period will be 6,638, or 3% greater than the housing requirement. We could not identify a more detailed trajectory setting out the timing and rate of delivery over the Plan period. In respect of deliverability specifically, it appears that the Link Road Site (Reference URB21) is unlikely to come forward within the first five year so f the Plan period. We would suggest that a start date of 2029.30 would be more realistic.

In respect of the five-year housing land supply generally, we could not find any evidence suggesting that a five year housing land supply would be established upon adoption of the emerging Local Plan.

Suggested Modifications: Changes Requested:

The Plan allocates insufficient growth to address affordable housing needs and there is no consideration of the link between the housing requirement and the objectively assessed need for affordable housing. In addition, the Plan contains insufficient flexibility to respond to changing circumstances and has not adequately tested higher options than the housing requirement through the SA process. The additional 5% introduced on top of the LHN is not evidence-led.

The housing requirement should be increased to address more affordable housing need and to provide a greater supply-side buffer. Higher growth options should be tested robustly within the SA against a distribution scenario to provide a more robust assessment of the effects of higher housing provision.

Request to be heard?: Yes

Reason for Request to be heard:Given our client's fundamental objections to the Plan, we request participation in the hearing sessions as part of the forthcoming Examination in Public (EiP).

Attachments: REP380-384 - Inside Land Group CO Marrons (PDF, 283 KB)(opens new window)

Rep ID: 383 / Respondent: Marrons on behalf of Inside Land Group Limited

Date Received: 1/31/2025

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy OSS1

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Does not comply with Duty to Co-operate

Reasons: Draft Policy OSS1 - Housing Growth (Location) Comments:

Draft Policy OSS1 articulates a broad distribution of growth. It specifies that 45% of growth will be directed towards the urban area of Great Yarmouth, Gorleston and Bradwell. 20% of growth will be directed to Caister-on-Sea, whilst 35% of growth will be directed to the villages.

The urban area is acknowledged has having the best potential for economic growth and has the best access to existing and emerging employment opportunities, services and facilities and is supported by a range of infrastructure. By contrast, the villages are acknowledged (paragraph 3.12 of the Plan) as having fewer services, facilities and employment opportunities.

Whilst there is no comprehensive settlement hierarchy methodology or background paper supporting the Plan's classification of settlements, its apportionment of 35% growth to the Borough's villages is significant, given that the Plan itself acknowledges that these are the least sustainable locations for growth in the Borough. The Plan will therefore deliver only 10% fewer dwellings in the villages then within the urban settlements and this is not reflective of a sustainable pattern of growth.

The spatial distribution options tested within the SA apportion at least 35% of growth to the rural area, apart from Option OSS1f: Restrict development in the rural areas, albeit even this option apportions 25% of all housing growth to the rural area. It is noteworthy that Option OSS1f performs almost identically to the preferred option, but the positive effects in relation to an urban-focused strategy (e.g. in relation to reducing multiple deprivation) have been understated.

Option OSS1f: is recorded as having an uncertain positive effect in relation to SA6 (improving accessibility to essential services and facilities), but it is unclear how this could be the case when it is the option that makes the best use of existing services and facilities. By contrast, the preferred option is recorded as having significant positive effects in this respect, which is questionable given the reliance on the least sustainable parts of the Borough to deliver 35% of housing over the Plan period. Likewise, in relation to

SA14 Option OSS1f would reduce the need to travel by virtue of concentrating new housing growth in locations accessible via sustainable means of transport.

In defence of the scale of its housing apportionment to villages, the Plan and the SA make reference to supporting rural service provision through additional housing. Whilst it is true that housing at rural settlements can underpin the viability of existing services and help to deliver new ones, there is nothing to suggest within the Plan or its evidence base that rural services and facilities would be under threat in the absence of the considerable amount of growth directed towards the rural areas.

For the above reasons, the spatial strategy is unjustified for lack of a robust SA process and not in conformity with national policy ,as it will not result in an overall pattern of growth that is sustainable nor or reduce the need to travel by private car. This would undermine the fundamental thrust of national policy which is to focus significant new development in locations which are or can be made sustainable.

Suggested Modifications: Change(s) Requested:

The Plan should increase the apportionment of housing growth in the urban area of Great Yarmouth, Gorleston-on-Sea and Bradwell in order to secure sustainable patterns of growth and align with the Plan's urban regeneration focused strategy and aspirations to reduce multiple deprivation. The SA process indicates that Option OSS1f is the best performing option equating to positive affects across a number of SA objectives when properly assessed. By contrast, the positive effects of the preferred option have clearly been overstated given the significant quantum of growth directed towards the rural areas and the corresponding negative effects in terms of encouraging sustainable travel patterns and addressing the challenges of climate change.

Request to be heard?: Yes

Reason for Request to be heard:Given our client's fundamental objections to the Plan, we request participation in the hearing sessions as part of the forthcoming Examination in Public (EiP).

Attachments: REP380-384 - Inside Land Group CO Marrons (PDF, 283 KB)(opens new window)

Rep ID: 384 / Respondent: Marrons on behalf of Inside Land Group Limited

Date Received: 1/31/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:General

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Does not comply with Duty to Co-operate

Reasons: Land North of Market Road, Bradwell - Comments on Site Selection Evidence

As set out above, our client is promoting the Land North of Market Road, Bradwell for residential development (Site Reference S62). In relation to the assessment of the Site against the SA objectives within the Great Yarmouth Local Plan Sustainability Report (Appendix C), we make the following observations:

• SA1 - Reduce multiple deprivation. The SA records that the Site is within a highly sustainable location, including in relation to primary and secondary schools. The observation that development of the Site would only result in limited "small-scale" affordable housing is clearly incorrect. The SA has appraised the Site for 420 homes and even a fraction of this number at a policy compliant level (i.e. 25%) would result in a significant quantum of affordable homes in a sustainable location where they are needed the most. The scoring should be upgraded from "minor positive" to "significant positive."

• SA2 - Reducing health inequalities. The SA records that most of the Site is within 800m of key services and facilities, including existing recreational opportunities. The close proximity of the Site. As such a significant positive effect should be recorded.

• SA6 - Improving accessibility. As set out the above, the Site is in a highly sustainable location close to key services and facilities. It will therefore encourage sustainable modes of travel and given its highly sustainable location, its development should be deemed to have a "significant" positive effect.

• SA7 - Biodiversity. We note the assessment which records a significant negative yet uncertain affect. It is welcome that mitigation has been concerned and that a significant positive effect is recorded against this objective with mitigation in place.

• SA8 - Landscape. This is discussed in further detail below. Suffice to say at this point, a "significant" negative effect is recorded, based on the findings of the Settlement Fringe Study.

• S10 - Historic environment. This is discussed in further detail below. Suffice to say at this point, a "significant" negative effect is recorded based on the presence of two Grade II listed farmhouses/barns north of the Site boundary, as well as the Breydon Water and Halvergate Marshes Conservation Area.

• S11 - Use of land. A significant negative effect is recorded on the basis that the development of the Site may lead to the loss of Grade 3a agricultural land (Best and Most Versatile or "BMV"). It is assumed that this assessment has been based on Natural England's agricultural land quality maps which are high-level only and cannot be relied upon to assess the classification of a single site. We would therefore suggest that this uncertainty is recognised within the SA.

• SA13 - Contribution to the reductions of carbon emissions. The Site is in a highly sustainable location in walking distance to local facilities and services. Given that this will encourage reliance on modes of transport other than the private car, it is clear that the Site will at least generate some positive effects against this objective, rather than having a neutral or negligible impact.

• SA16 - To encourage efficient patterns of movement. Once again, only a minor positive effect against this objective has been recorded. This aspect of the appraisal fails to recognise the robust sustainability credentials of this location.

Landscape Effects:

Both the SA and the Housing and Economic Land Availability Assessment (HELAA) record a significant negative effect on landscape, owing to the proximity of the Site to the Broads, which is located toward its northern boundary. To address this matter, our client has previously submitted to the Regulation 19 Consultation a Landscape and Visual Advice Note by SLR Consulting dated 3rd May 2024.

The Advice Note concludes that the Site is not monolithic in its contribution towards the setting of the Broads. There are significant areas of the Site (namely along the frontage with Market Road) which do

not contribute significantly landscape setting of the Broads and are instead more closely influenced by the built edge of the settlement. Whilst the findings of the Settlement Fringe Study in respect of the Broad Parcel within which the Site is located, this relates to a large area of land which includes a substantial amount of land area outside of the Site. Apart from the Advice Note submitted to the Council during the previous consultation, which does not appear to have been taken account of in the current consultation material, no part of the evidence base has looked at the individual performance of the Site in respect of landscape and visual matters. Relying on the Settlement Fringe Study alone given the broad scale at which this part of the evidence base considers landscape matters is not a robust approach, particularly not when the Site performs very well in most other respects.

As set out above, the SA considers potential for mitigation, which is welcome, but the findings of the Settlement Fringe Study are used to justify a conclusion that no development apart from one very minor in scale would be capable of adequately mitigating the harmful effects to landscape. With respect, this conclusion is not substantiated by the evidence nor is it informed by the evidence submitted to the Council in the form of the Advice Note, which clearly shows opportunities for significant new planting and landscape creation which would filter and soften views.

As such, we consider that the significance of the landscape harm assumed and the capacity to mitigate it has not been appropriately assessed and undermines the robustness of the SA process and the content of the Plan.

Heritage:

The SA records a significant negative impact in relation to heritage matters. This assessment arises from the presence of two Grade II listed farmhouses/barns situated to the north of the Site boundary. The rural landscape surrounding these assets has been assessed as being "inexorably linked" to the assets themselves. Therefore, mitigation measures have been deemed as unlikely to improve the performance of any major development in respect of heritage.

As part of the previous consultation, our clients submitted a Heritage Assessment by Richard Hoggett Heritage. The assessment clearly sets out that the assumed "substantial harm" to the setting of the heritage assets is simply incorrect, as development of the Site would only affect the setting of these assets at most and would not result in any alterations or changes to their fabric. As such, substantial harm simply cannot occur. Therefore, the HELAA and the SA's assessment of the Site has clearly misapplied national policy in respect of assessing impact on setting, which significantly undermines the credibility and robustness of the SA process.

The Heritage Assessment concludes development of the Site would likely cause less than substantial harm from eroding the agricultural landscape around the assets which would, in turn, have an impact on their setting. This would equate to less than substantial harm, which then must be weighed in the planning balance against the public benefits of the scheme. This exercise has not been undertaken.

As to the scope for mitigation, the SA considers that the harm to the heritage assets cannot be mitigated and appears to have disregarded paragraph 5.4 of the Heritage Assessment, which states (in a similar vein to landscape) that the impact to the setting of the heritage assets can be addressed by pulling the northern edge of the development back from the heritage assets, as well as retaining and bolstering the current wooded hedgerows, which separate the assets from the Site. This strategy is reflected in the Landscape Appraisal prepared by SLR, which the LPA has not had regard to.

The SA's conclusion that harms to heritage assets cannot be mitigated is simply incorrect and not based upon any robust technical assessment.

Suggested Modifications: Summary s Conclusion

The Plan is unsound for the following reasons:

• The housing requirement does not address the need for affordable housing nor has any consideration been given to accommodating a level of growth above the minimum amount required by the LHN;

• Despite the reliance upon transitional provision in the NPPF24, no clear commitment has been made to reviewing the Plan to address the shortfall in housing numbers, as required by the NPPF24.

• The housing requirement is inadequate to meet defined affordable housing needs;

• The housing requirement is inadequate to address economic growth;

• The Plan has disregarded its own spatial strategy by directing a considerable proportion of housing growth away from the more sustainable settlements like Bradwell towards the rural area;

• There is insufficient flexibility within the Plan's overall housing land supply to respond to changing circumstances; and

• The site assessment process has not been robust. Despite the copious evidence submitted to the LPA through previous consultations, the content of site assessment evidence has not changed at all to reflect this material.

For the above reasons, we object to the Plan as published as it is unsound. It is unlikely that the Plan can be made sound through modifications within a realistic timescale, but we have made recommendations above where applicable. Given our client's fundamental objections to the Plan, we request participation in the hearing sessions as part of the forthcoming Examination in Public (EiP).

Request to be heard?: Yes

Reason for Request to be heard:Given our client's fundamental objections to the Plan, we request participation in the hearing sessions as part of the forthcoming Examination in Public (EiP).

Attachments: REP380-384 - Inside Land Group CO Marrons (PDF, 283 KB)(opens new window)

Rep ID: 385 / Respondent: Ministry of Defence Chris Waldron

Date Received: 1/31/2025

Section of the Plan: 14

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CLC4 and General

Sound/Legally Compliant/Duty to Co-operate Response:Not specified

Reasons: It is understood that Great Yarmouth Borough Council are undertaking a Regulation 19 consultation regarding their pre-submission final draft of the Great Yarmouth Local Plan.

The Defence Infrastructure Organisation (DIO) Safeguarding Team represents the MOD as a statutory consultee in the UK planning system to ensure designated zones around key operational defence sites such as aerodromes, explosives storage sites, air weapon ranges, and technical sites are not adversely affected by development outside the MOD estate.

For clarity, this response relates to MOD Safeguarding concerns only and should be read in conjunction with any other submissions that might be provided by other MOD sites or departments.

Paragraph 102 of the National Planning Policy Framework (December 2024) requires that planning policies and decisions take into account defence requirements by 'ensuring that operational sites are not affected adversely by the impact of other development proposed in the area.' Statutory consultation of the MOD occurs as a result of the provisions of the Town and Country Planning (Safeguarded aerodromes, technical sites and military explosives storage areas) Direction 2002 (DfT/ODPM Circular 01/2003) and the location data and criteria set out on safeguarding maps issued to Local Planning Authorities by the Ministry of Housing, Communities & Local Government (MHCLG) in accordance with the provisions of that Direction.

The area covered by any Great Yarmouth Local Plan is washed over by safeguarding zones that are designated to preserve the operation and capability of Remote Radar Head (RRH) Neatishead.

Copies of these relevant plans, in both GIS shapefile and .pdf format are issued to Local Planning Authorities by MHCLG. An assurance review was conducted by the MOD in 2023 which confirmed that, at that time, Local Planning Authorities held the most recent relevant safeguarding data. Any subsequent updates to those plans were then issued by MHCLG. If there is a requirement for replacement data, a request can be made through the above email address

The review or drafting of planning policy provides an opportunity to better inform developers of the statutory requirement that MOD is consulted on development that triggers the criteria set out on Safeguarding Plans, and the constraints that might be applied to development as a result of the requirement to ensure defence capability and operations are not adversely affected.

To provide an illustration of the various issues that might be fundamental to MOD assessment carried out in response to statutory consultation, a brief summary of the main safeguarding areas of concern is provided below. Depending on the statutory safeguarding zone within which a site allocation or proposed development falls, different considerations will apply.

Technical assets that facilitate air traffic management, primarily radar, navigation, and communications systems are safeguarded to limit the impact of development on their capability and operation. The height, massing, and materials used to finish a development may all be factors in assessing the impact of a given scheme. Developments that incorporate renewable energy systems may be of particular concern given their potential to provide large expanses of metal at height, for example where proposals include a wind turbine or roof mounted solar PV system.

Where development falls outside designated safeguarding zones the MOD may have an interest where development is of a type likely to have any impact on operational capability. Usually this will be by virtue of the scale, height, or other physical property of a development. Examples these types of development include, but are not limited to

oAny development that would exceed a height of 50m above ground level. Both tall (of or exceeding a height of 50m above ground level) structures and wind turbine development introduce physical obstacles to low flying aircraft; and

o Any development, including changes of use and regardless of height, outside MOD safeguarding zones but in the vicinity of military training estate or property.

Within the Policy CLC4: Renewable and Low-Carbon Energy Development Proposals (Pg 283), the MOD notes and welcomes the provision "Proposals for renewable energy and low-carbon schemes and associated ancillary development will be permitted where the individual or cumulative impacts are or will be made acceptable in respect of all of the following: section e "Air traffic safety, radar, reflected light and telecommunications"

The MOD has, in principle, no objection to any renewable energy development, though some infrastructure enabling renewable energy production, for example wind turbine generators or solar photo voltaic panels can, by virtue of their physical dimensions and properties, impact upon military aviation activities, cause obstruction to protected critical airspace surrounding military aerodromes, or impede the operation of safeguarded defence technical installations.

Solar PV development can impact on the operation and capability of communications and other technical assets by introducing substantial areas of metal or sources of electromagnetic interference. Depending on the location of development, solar panels may also produce glint and glare which can affect aircrew or air traffic controllers.

In addition, where turbines are erected in line of sight to defence radars and other types of defence technical installations, the rotating motion of their blades can degrade and cause interference to the effective operation of these types of installations potentially resulting in detriment to aviation safety and operational capability. This potential is recognised in the Government's online Planning Practice Guidance which contains, within the Renewable and Low Carbon Energy section, specific guidance that both developers and Local Planning Authorities should consult the MOD where a proposed turbine has a tip height of, or exceeding 11m, and/or has a rotor diameter of, or exceeding 2m.

Additionally, it may be necessary in certain circumstances for MOD to require the removal of permitted development rights, where the use of these rights introduces elements that would not be compatible with MOD safeguarding requirements.

I trust this clearly explains our position on this update. Please do not hesitate to contact me should you wish to consider these points further.

Suggested Modifications: -

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: REP385 - Ministry of Defence (PDF, 140 KB)(opens new window)

Rep ID: 386 / Respondent: Home Builders Federation Mark Behrendt

Date Received: 1/31/2025

Section of the Plan: 1

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:General

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound

Reasons: The assumption made by the Council in 1.6 of the report to full Council on the 17th of October 2024 was that local plan would be examined under the 2023 National Planning Policy Framework (NPPF23) on the basis that the plan had reached regulation 19 consultation within one month of the 2024 Framework (NPPF24) being published and was within 200 dwellings per annum (dpa) of the proposed requirement. However, these assumptions were made on the basis of the draft NPPF24. However, the transition arrangements in paragraph 234a of final NPPF24 published in December state:

"a. the plan has reached Regulation 1982 (pre-submission stage) on or before 12 March 2025, and its draft housing requirement meets at least 80% of local housing need"

The Council are proposing a housing requirment of 380 dpa which is 72% of the local housing needs assessment using the latest standard of 525 dpa. Therefore, in order for the plan to be examined under NPPF23 the Council will need to have submitted the plan by the 12th of March 2025. On the basis of the report to full council referred to above it is evident that the Council's intention is for this plan mot be examined under NPPF23. However, in order to achieve this the Council has just 6 weeks to process all representations and properly consider the soundness issues raised by these representations prior to submission. HBF are therefore concerned that the Council will not give due regard to the outcomes of the regulation 19 consultation prior to submission in the rush to submit the plan prior to the 12th of March in their desire to limit the number of homes it must plan for. It is important that the Council has all the necessary submission documents and evidence base in place and it does not seek to try and address any short comings in the plan raised during this consultation after it has been submitted.

As the Council will be aware the Government has told the Planning Inspectorate that "Any pauses to undertake additional work should usually take no more than six months overall. Pragmatism should not be used to address fundamental issues with the soundness of a plan, which would be likely to require pausing or delaying the examination process for more than six months overall". As such if there is any risk of delay in the examination then the Council must not submit this local plan and delay the reparation of a local plan that meets the needs of the Borough in full is required by the latest iteration of the NPPF and the standard method for housing needs it promotes.

Suggested Modifications: If the plan is submitted prior to the 12th of March and examined under NPPF23 then HBF consider it essential that there is a review policy in the local plan that commits the Council to an immediate review. However, in order to ensure that this is actually undertaken this policy will need to have consequences. HBF suggest a polciy similar to that adopted in the Bedford Local Plan 2030, which was examined under the transition arrangements in the 2019 NPPF. This policy required the Council to submit a new plan within three years of adopting the local plan 2030 and in the event that this submission date is not adhered to, the policies in the local plan which are most important for determining planning applications for new dwellings will be deemed to be 'out of date'. Such a policy would ensure that the plan is consistent with paragraph 236 of the implementation arrangements in the NPPF24 which states that LPAs are expected to begin work on a new plan in order to address the shortfall in housing need. Whilst the NPPF24 does require local plans that are not within 80% of housing needs to include 20% buffer in its assessment of housing needs from July 2026 the HBF do not consider this to be sufficient sanction for Great Yarmouth.

Request to be heard?: Yes

Reason for Request to be heard:Please see attached letter setting out the HBF's concerns regarding the soundness of the local plan.

Attachments: REP386-392 - Home Builders Federation (PDF, 392 KB)(opens new window)

Rep ID: 387 / Respondent: Home Builders Federation Mark Behrendt

Date Received: 1/31/2025

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy OSS1

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound

Reasons: This policy is unsound as it is unjustified and not positively prepared.

Housing requirement

The Council are proposing a housing requirment 380 dpa - a total of 6,460 homes over the plan period 2024 to 2041. To meet this requirment the Council expect approximately 6,640 homes to be delivered from existing commitment and on the sites allocated in this local plan.

Turning to the housing requirment the Council outline that this is based on the standard method set out in Planning Practice Guidance which result in a local housing need of 353 dpa. However, as this is lower than the current local plan requirment of 363 and in recognition of the need to boost housing supply, as stated in paragraph 60 of the NPPF, the Council have chosen to maintain the current housing requirement of 363 dpa and uplift it by 5%, resulting in a housing requirment of 380 dpa. While HBF welcomes the decision to increase the housing requirment it is not clear why 5% was chosen. A cynical person may conclude that this was an attempt by the Council to benefit from the transition arrangements that were initially set out in the draft NPPF published for consultation in the summer of 2024, given that it lifts the housing requirment to less than 200 homes of the proposed local housing need at that time of 569 dpa.

If the Council's desire to boost housing supply is taken at face value it would be helpful to understand why a 5% uplift was chosen and not, 10%, 15% or even 20%. One approach for example, would be to uplift the requirment to deliver more affordable housing. PPG states at paragraph 2a-024-20190220 that an increase in the total housing figures included in the plan may need to be considered where it could help deliver the required number of affordable homes. The Council state in paragraph 7.3 of the local plan that there is a need for 130 affordable homes each year - approximately 37% of total needs. On the basis that qualifying sites can only viably deliver 25% of their homes as affordable this would suggest a shortfall of at least 42 homes per annum against the 353 dpa minimum arrived at by the standard method. In order to address this shortfall would require an 12% uplift and a requirment of 395 dpa. In reality the shortfall is likely to be even greater given that affordable homes are only required on sites of 10 or more units so this is the minimum uplift that would be needed to boost the supply of homes in Great Yarmouth. However, even this figure is substantially below the number of homes the Council will be expected to plan for in preparing the next iteration of the local plan.

The Council have considered a higher supply in the Sustainability Appraisal. Option OSS1h appraised the potential impact of a supply that was 33% higher than the requirment proposed in the preferred approach (OSS1). The conclusion was that this the negative impacts on agricultural land and landscape means that the option is not preferred. However, the assumptions made in the SA in relation to higher housing growth appears to ignore the potential benefits. For example, with regard to objective 1 reducing multiple deprivation no mention is made as to the significant positives of the increase in affordable housing that would result from this option nor the health benefits this would have in relation to objective 2. To suggest as the council has that there will be no effect seems absurd. Similarly, to suggest that there would be no effect on town centre vitality and viability (objective 17) fails to recognise that and increase in housing would have a positive effect on centres, as is suggested by the Council with regard to its preferred approach. If anything, more housing would have a greater positive effect due to the increase in population.

HBF are therefore concerned that its approach to the proposed uplift has failed to properly consider growth beyond what is being proposed in OSS1 and why only a 5% uplift is considered necessary to boost housing supply in Great Yarmouth. Whilst a boost to housing delivery is clearly required there is robust evidence to suggest that this should be higher than 5% being proposed by the Council.

Housing Supply

As required by national policy the Council have included a trajectory in Appendix 8 of the local plan. This indicates that total supply of homes over the plan period will be at least 6,638. This is 178 (circa 3%) more than the housing requirement. This is a relatively small buffer between needs and supply to be certain that as a minimum housing needs will be met over the plan period, as is required by paragraph 36a of the NPPF. However, HBF note paragraph 3.6 of the local plan which outlines that this does not include an allowance for windfall which would potneitally add a further 875 homes over the plan period. This level of windfall would mean supply being circa 16% higher than the housing requirment and within the range of what HBF expect to ensure robust supply over the plan period.

With regard the housing supply we would suggest a more detailed trajectory isa provided in the submission evidence. While the trajectory in appendix sets out the delivery expectations on each of the allocated sites a similar trajectory should be provided for the other sites that make up supply over the plan period. With regard to the deliverability of the sites in the trajectory HBF question would be whether the Link Road site (URB21) come forward in the first five years. While an EIA screening assessment has been concluded recently no planning application has been submitted. The latest Start to Finish1 report published by Lichfields indicates in figure 3.2 that the average time from submission of an application to the first completion on a site of this size to be nearly five years. While this is an average and the site could come forward more quickly HBF would suggest that a start date of 2029/30 is a more realistic timeframe.

Finally, HBF could not find an assessment of the Council's five year land supply on adoption, this will need to be provided by the Council.

Small sites of less than 1 hectare

The NPPF requires Local Plans to identify land to accommodate at least 10% of the housing requirement on sites no larger than one hectare, unless there are strong reasons why this cannot be achieved. The HBF has undertaken extensive consultation with its small developer members. One of the chief obstacles for small developers is that funding is extremely difficult to secure without a full, detailed, and implementable planning permission. Securing an implementable planning permission is extremely difficult if small sites are not allocated. Without implementable consents lenders are uneasy about making finance available or the repayment fees and interest rates they set will be very high. Small developers, consequently, need to invest a lot of money and time up-front in the risky business of trying to secure an allocation and a planning permission, and this is money that many small developers do not have.

The HBF would therefore wish to see the 10% small sites allowance delivered through allocations (and not windfall). Such sites are important for encouraging the growth in SME housebuilders who will tend to develop these sites but rarely see the benefits that arise from the allocation of sites in a local plan. Up until the 1980s, small developers accounted for the construction of half of all homes built in this country resulting in greater variety of product, more competition, and faster build-out rates. Since then, the number of small companies has fallen by 80%.

Suggested Modifications: -

Request to be heard?: Yes

Reason for Request to be heard:Please see attached letter setting out the HBF's concerns regarding the soundness of the local plan.

Attachments: REP386-392 - Home Builders Federation (PDF, 392 KB)(opens new window)

Rep ID: 388 / Respondent: Home Builders Federation Mark Behrendt

Date Received: 1/31/2025

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy OSS4

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound

Reasons: This policy is unsound as it is inconsistent with national polciy, unjustified and ineffective.

At the end of this policy, it is stated that development will not be permitted where it would have a significant effect on the capacity of existing infrastructure and therefore creates a risk to the environment, economy or society. This is a very broad statement and while HBF understands the need to ensure that there is sufficient capacity to support development this is the role of the local plan. While such policies seem reasonable perceived issues with capacity are being used elsewhere to refuse development. In Sussex for example Wealden Council are refusing to discharge conditions relating to the capacity of the waste water treatment network despite the water company considering there to be sufficient capacity.

The need to plan for the infrastructure needs of an area is an essential part of the planning for new development but issues of capacity must be considered and addressed as part of plan making and not for further consideration at the application stage. If the Council do not consider there to be sufficient capacity in the areas infrastructure to meet development needs, then that is a show stopper, and the plan should be found unsound.

Suggested Modifications: However, HBF recognise that there may be changes in circumstance but the issue of capacity and the impact of a development on that capacity must be for the infrastructure provider to determine as part of the statutory consultation. HBF therefore propose the final paragraph is amended to as follows:

"Development will not be permitted where the relevant statutory consultee has determined that it would have a significant effect on the capacity of existing infrastructure, and therefore creates potential risks to the environment, the economy or society which cannot be mitigated."

Request to be heard?: Yes

Reason for Request to be heard:Please see attached letter setting out the HBF's concerns regarding the soundness of the local plan.

Attachments: REP386-392 - Home Builders Federation (PDF, 392 KB)(opens new window)

Rep ID: 389 / Respondent: Home Builders Federation Mark Behrendt

Date Received: 1/31/2025

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy OSS5

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound

Reasons: This policy is unsound as it is inconsistent with national policy.

HBF consider the approach in this policy is inconsistent with paragraph 59 of the NPPF in that limits the scope on which viability matters can be considered solely on the basis of an increase in the cost of planning obligations on development.

Paragraph 59 of the NPPF which states that whilst the weight given to a viability assessment is a matter for the decision maker this followed by "having regard to all the circumstances in the case, including whether the plan and the viability evidence underpinning it is up to date, and any change in site circumstances since the plan was brought into force". Therefore, as written this policy would prevent the decision maker from considering any of other changes in a sites circumstances isolating them solely to the cumulative cost of planning obligation.

Suggested Modifications: The policy should be amended to:

"Development viability with respect to planning obligations and other planning policy requirements will only be considered as a justification for lowering levels of contributions affordable housing or departing from other planning policy requirements where there has been a change in circumstances affecting that site. Particular regard will be given to the following circumstances: ..."

Request to be heard?: Yes

Reason for Request to be heard:Please see attached letter setting out the HBF's concerns regarding the soundness of the local plan.

Attachments: REP386-392 - Home Builders Federation (PDF, 392 KB)(opens new window)

Rep ID: 390 / Respondent: Home Builders Federation Mark Behrendt

Date Received: 1/31/2025

Section of the Plan: 7

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HOU6

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound

Reasons: The policy is unsound as it unjustified and not effective.

This policy requires sites of 200 or more dwellings to set aside 5% of plots to provider for self and custom build housing in order to address what is a relatively small demand for self- build plots of 6 dpa. However, what is not apparent is whether the Council has looked at other approaches to increasing self-build plots other than the polciy being proposed. Paragraph 57-025-20210508 of PPG sets out how local authorities can increase the number of planning permissions which are suitable for self and custom build housing. These include supporting neighbourhood planning groups to include sites in their plans, effective joint working and using Council owned land.

HBF considers that such approaches should have been at least considered as a means to ensure a reliable and sufficient provision of self & custom build opportunities across the area. In addition, the Council could have looked identify and allocate small and medium scale sites specifically for self & custom build housing on sustainable sites especially if the proposal would round off the developed form and provided a boost to housing supply rather than simply changing who constructs a dwelling on a strategic allocation. However, looking at the SA the only alternative that appears to have been considered to this policy is to have no policy3. In order for this approach to be considered sound the Council must be able to show that it has considered alternative approaches to meeting the identified demand for self-build plots.

However, if a self-build policy is be pursued, then HBF agree that if demand for plots is not realised, it is important that plots should not be left empty to the detriment of neighbouring properties or the whole development. The timescale for reversion of these plots to the original housebuilder should be as short as possible from the commencement of development because the consequential delay in developing those plots presents further practical difficulties in terms of co-ordinating their development with construction activity on the wider site. There are even greater logistical problems created if the original housebuilder has completed the development and is forced to return to site to build out plots which have not been sold to self and custom builders. The HBF would therefore suggest that any unsold plots should revert to the original developer after a six-month, not twelve-month marketing period.

Suggested Modifications: -

Request to be heard?: Yes

Reason for Request to be heard:Please see attached letter setting out the HBF's concerns regarding the soundness of the local plan.

Attachments: REP386-392 - Home Builders Federation (PDF, 392 KB)(opens new window)

Rep ID: 391 / Respondent: Home Builders Federation Mark Behrendt

Date Received: 1/31/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT3

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound

Reasons: The policy is unsound as it unjustified and not effective.

This policy requires all major development to deliver a 20% net gain in biodiversity, compared to the 10% required by the Environment Act 2021. The exception to this is brownfield within the areas listed in the policy which will not have to provide BNG above the statutory requirment.

In considering the soundness of this policy it is necessary to consider paragraph 74-006- 20240214 of PPG which states that:

"... plan-makers should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, either on an area-wide basis or for specific allocations for development unless justified. To justify such policies, they will need to be evidenced including as to local need for a higher percentage, local opportunities for a higher percentage and any impacts on viability for development. Consideration will also need to be given to how the policy will be implemented".

It is important to note that the starting point is that local plan should not seek a higher requirement. This is different to a permissive policy allowing local plans to seek a higher level of BNG where justified, and the HBF would argue that it should be considered a high bar with regard to the evidence required to justify such a policy. There must be a very clear and robust justification that the area is significantly worse than the country as whole and that this decline is directly related to the new development rather than, for example, the result of changes in agricultural practices or industrial pollution. It is not sufficiently robust to highlight declines in species that whilst an important issue is not necessarily as a result of new homes being built.

The HBF does not disagree that the UK has seen a loss in biodiversity not just in recent past but previous centuries and as such recognise the importance of ensuring that the outcome of new development in future is that there is a net gain in biodiversity. However, it is important to recognise that in recent years new residential development has not been the driver of declining biodiversity either locally or nationally and in particular over the last 50 years. The main drivers of declining biodiversity in England, as outlined in the State of Nature Report 2023 (State of Nature Partnership, 2023), as being "Intensive management of agricultural land, largely driven by policies and incentives since World War II, has been identified as the most significant factor driving species' population change in the UK". Therefore, whilst it is important for development to ensure that it improves the natural environment the main driver of biodiversity it is important to also recognise it is not a significant driver of biodiversity decline in Great Yarmouth.

The justification provided by the Council for going beyond the 10% statutory requirment is that only 8.2% of the land within the Borough that is specifically protected for wildlife through designations such as SSSIs. While HBF do not dispute this we do not see why this is justification for requiring development to deliver a higher level of biodiversity net gain than that required by the Environment Act. Similarly, HBF cannot see why a high tree equity score is justification the proposed uplift in BNG. The fact that the area may benefit from tree planting is not a justification for asking for a higher level of BNG than the statutory minimum - especially given that tree planting may not be the outcome of delivering more BNG. The type of habitat that is provided will focus on replacing the type of habitat lost - this may not necessarily be through plating more of trees. The evidence presented by the Council therefore provides no justification for going beyond 10% and certainly not sufficient to overcome what HBF consider must be a high bar given for such policies.

The Council must also be able to show that the 20% net gain is viable and will not compromise the deliverability of sites or the local plan as a whole. The Viability Assessment (VA) bases the cost assumptions for BNG on research commissioned by Kent County Council which suggests that the cost of delivering 20% will not be significantly more than the statutory 10% minimum. However, in considering the cost of delivering BNG it must be recognised this will depend significantly on the type and extent of the different habitats found on site. Some sites will find it relatively simple to delver 10% onsite others will find it more difficult and require significantly higher levels of site delivery which increases costs significantly. Therefore, it is concerning that in referring to the research by Kent County Council the VA does not outline that the cost of off-site credits used in that study are based on the 2019 DEFRA Impact Assessment which assumed costs of these at £11,000. However, our members are experiencing costs of over £30,000 per unit with the cost varying based on the habitat type and the where the offsetting units is being delivered. Given that any BNG required in addition to the statutory minimum is likely to require more offsetting, then the VA could be underestimating the cost of this policy.

If the 20% requirement is considered to be sound it will be necessary for soundness that flexibility is included in the local plan with regard to the percentage of net gain required above the statutory minimum. The policy should clearly state that where this is impacting the viability and deliverability of a development that any BNG requirement will be reduced to the 10% statutory minimum.

Turning to other aspects of the policy HBF it is not clear what the Council means the second sentence of the fourth paragraph when it states, "Where 20% net gain is required at least 10% (the non-statutory element should be delivered on-site)". Firstly, this will need to be rewritten to make sense. Secondly if we assume that this means that sites should deliver at least 10% of the required net gains on site and that the on site gains must relate to the non- statutory element then it is not clear why the non-statutory element of the net gains required should be delivered on site. Without further details as to what the council intends with this statement the HBF does not consider the approach to be consistent with paragraph 16 of the NPPF which requires policies to be clearly written and unambiguous.

With regard to offsite delivery of net gain the policy states that these will only be considered,

"...where it can be demonstrated that, after following the biodiversity gain hierarchy, all reasonable opportunities to achieve measurable net gains on-site have been exhausted or where greater gains can be delivered off-site where the improvements can be demonstrated to be deliverable and are consistent with the Local Nature Recovery Strategy ensuring current ecological networks are not compromised and future improvement in habitat connectivity are not prejudiced".

The HBF do not consider it strictly necessary for the Council to reiterate requirements that are already set out in both the legislation and the supporting guidance in PPG. However, if reference is to be made as to the balance between on site and off site delivery the Council must also recognise that there will be circumstances where off site delivery may need to be outside of locations identified in the LNRS and indeed outside of the Borough altogether. It might be preferable for delivery to be as suggested in the policy but if this is not possible then the policy must clearly state that other solutions are acceptable, as set out in paragraph 74-008-20240214 of PPG. This is particularly important if the 20% net gain is considered to be sound given that this will most likely result in an increased need for offsite solutions.

Suggested Modifications: -

Request to be heard?: Yes

Reason for Request to be heard:Please see attached letter setting out the HBF's concerns regarding the soundness of the local plan.

Attachments: REP386-392 - Home Builders Federation (PDF, 392 KB)(opens new window)

Rep ID: 392 / Respondent: Home Builders Federation Mark Behrendt

Date Received: 1/31/2025

Section of the Plan: 14

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CLC3

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound

Reasons: Policy is unsound as it is inconsistent with national policy.

Part a of this policy which requires applicants to demonstrate that adequate foul water treatment and drainage exists is not considered to be sound. Section 106 of the Water Industry Act 1991 S106 sets out that the owner of any domestic property is entitled to have foul and surface water from their property connected to the public sewerage system and as such the matter is not one of land use planning to be considered through development management.

However, HBF do recognise that it is an issue to be considered at plan making and it is for the water company to consider whether current drainage and water treatment infrastructure can support expected levels of development. Such considerations have been made with paragraph 5.2.3 of the Infrastructure Needs Study stating there is sufficient capacity to accommodate future housing growth. If unforeseen events occur meaning that the water company is unable to provide the water services required, then the local authority must reflect those problems through amendments to its local plan. If water services cannot be guaranteed, then the development requirements in the local plan cannot be delivered. Consequently, the local plan is unsound. The plan cannot be made sound in relation to matters of water through policies in a plan that seek consider such matters on a case by case basis. Therefore, HBF recommend that part a of the policy should be deleted as it is not consistent with the legal framework governing the supply of wastewater services to new development.

Suggested Modifications: HBF recommend that part a of the policy should be deleted as it is not consistent with the legal framework governing the supply of wastewater services to new development.

Request to be heard?: Yes

Reason for Request to be heard:Please see attached letter setting out the HBF's concerns regarding the soundness of the local plan.

Attachments: REP386-392 - Home Builders Federation (PDF, 392 KB)(opens new window)

Rep ID: 393 / Respondent: MariaTheresia Saiko

Date Received: 1/31/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB25

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Complies with Duty to Co-operate

Reasons:

Sadly we live in a time where nature is struggling to survive on its own and increasingly relies on human compassion to exist, particularly in urban areas.

I moved to Gorleston-on-Sea in 2015 after visiting here multiple times since 2007. At the time I felt that I was moving into a nice little town, which not only offers a great beach but also many green spaces for recreation, which equally encourage and nurture wildlife. All this of course also supports residents' mental health.

Since knowing this town and its surrounding areas, I have seen the new housing developments along Beaufort Way taking over an area I had previously known to be an amazing attribute and wildlife haven.

Currently the new planned developments on the opposite side of the road are threatening the beautiful area that is Bluebell Wood and its adjacent fields, again an important place for wildlife. Again wild animals will lose their habitat and will be forced to move on. Higher concentration of the same species in a smaller area invariably leads to scarcity of food sources which in turn leads to fewer new births. By animals, I am not only talking about mammals and birds. I am also including insects. Butterflies, moths, bees and more are already in decline here in Gorleston-on-Sea.

Additionally, this town lacks a supermarket with more accessible pricing. More developments will only contribute to more inhabitants suffering from the cost of living. Gorleston and Bradwell are being swamped with more and more inhabitants and the infrastructure is not being upheld. At this rate we will need staffed NHS dentists, an additional Secondary School et al.

Please would you kindly re-think the effect of the small housing development that is URB25. I wonder if it is being put there in order to finance an extension to the adjacent Primary School.

Please cancel plans to offer this land for housing development. If well maintained (and why not ask the community for volunteers?), this small woodland space wedged between a charming park (as listed on the 'visit Great Yarmouth' website) and nice open recreation ground, will not only benefit community mental health, but also enchant generations of residents with its beauty and wildlife.

Thank you for reading to the end. I sincerely hope that you will take my points into serious consideration.

M. Saiko.

Suggested Modifications: See above

Request to be heard?: No

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 394 / Respondent: RSPB Romy Hallworth

Date Received: 1/31/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB25

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Policy OSS1 and OSS2

The site on URB25 is the wrong location to build 70 houses as it is an area of natural woodland occupied by various wildlife and vegetation. Below is why:

The area that is left wild is occupied by various wildlife such as deer, foxes, hedgehogs and birds that already are facing pressure and have limited places to go, to take this away would be inhumane. It is covered with an extensive range of fruit trees and negation that provide a food source for the animals to depend upon.

Not only is it an area for wildlife, but is also appreciated by local dog walkers who may not have a car, nature enthusiasts and children who enjoy the outdoors. Studies suggest that green spaces have a positive impact on peoples mental health, not crammed in, poorly built, concrete jungles.

The woodland area is also a site of great historic interest, with the East Anglian School for the blind and deaf opening in May 1912 for 73 years. It became the responsibility of Great Yarmouth Borough Council in 1974 and was wrongly torn down to make way for a new housing estate (East Anglian Way) and school (St. Mary's Catholic Primary School) with now only a blue plaque left to remember the history on Church Road.

In the pre-submission plans (Page 97, Section 4.246) it mentions of significant World War II remains that were once there such as balloon barrage sites and weapon pits and the need for an archeological assessment to understand the value of any potential remains. With its history and wildlife, this area should be preserved.

It is also well known that the Acle Straight has not been worked on due to an endangered species of snail. Have thorough checks been made to ensure there aren't any protected species of plants, trees or animals in the woodland?

With hundreds of houses being built (such as Bluebell Meadow) and our infrastructure already facing issues, how is it going to cope when thousands more join? This little area of woodland is the only wild habitat left in Gorleston, why does it have to be destroyed for the sake of 70 more houses.

Policy OSS3

The development of these houses would be a direct violation of OSS3 (b) - a forestry development of mother nature's own making and would have a detrimental impact on the biodiversity of the woodland.

Paragraph 4.242 states that 2 acres of land will be used to 'facilitate improvements to St Mary's and St Peters Catholic School' with future developments such as an expansion or pick up/off point. Instead, why not preserve the woodland to be used as an area for outdoor learning for the children so that they know what it's like to see a fox and pick berries and appreciate what mother nature has given us

Policy OSS4

The infrastructure in place cannot support the addition of 70 more houses being built on site URB25, here is why;

There is no NHS dentist in Gorleston, the closest being Bradwell and Great Yarmouth

The only Doctors in Gorleston is Beaches Doctor Surgery and is already oversubscribed. This leaves Millwood surgery in Bradwell which is at its limit with an additional 800 houses being built, and Park Surgery in Great Yarmouth redrawing their catchment area and removing residents of Bradwell from again being oversubscribed.

Para 4.245 and 4.257 highlight the issues of flooding and drainage and that a strategy is needed to accommodate this, proving that the infrastructure is not in place to support it. Drainage is already a problem in Great Yarmouth and is regularly reported that the sewerage floods onto Gorleston Beach, the addition of another 70 houses would only make it worse. Borough Road, close to the site, was shut for months due to sewage issues.

Traffic and cars are a big problem in estates such as East Anglian Way around school time, with their narrow roads making it easy to block and congest meaning that emergency services would not be able to get though if needed. More houses in this area will only make intensify the problem.

Policy NAT1

This policy states the strategies in place to protect the biodiversity of the area. The best strategy would be to leave the area alone. Human interference will only ruin it and scare all the animals away. NAT4 - paragraph 4.248 and 4.249 already highlight issues connected to this natural habitat

Suggested Modifications: I oppose the building plan as a whole and should not go ahead. Here is why;

Policy OSS1

I believe no buildings should be built here so that wildlife have somewhere to hide and eat, so that they can reproduce and sustain future populations. It should be left how it is and protected for the mental and physical well-being of the locals who may not be able to get to other green spaces. The site also has a history, dating back to Second World War, giving it another reason to be preserved.

It is well known that we are destroying the world and land it holds, so why join in with every other statistic and not work to save what's left for our future! The government put £683 million into conservation in 2022/23 so why is this being contradicted and wasted by the council. Studies suggest that green spaces have a positive impact on peoples mental health. Being crammed into poorly built, concrete jungles is depressing and will have a negative impact on peoples wellbeing and house values.

Policy OSS4

It is common sense and clear to see that we haven't got the infrastructure to support the addition of 70 houses at URB25 and other surrounding areas. We are already overrun and facing problems, such as not even being able to get a doctors appointment or stuck in traffic because we haven't got the roads to accommodate busy times. This development should not go ahead as it will only worsen matters and put pressure on the locals that have lived here all their lives.

Policy NAT1

The best strategy to protecting the biodiversity is to LEAVE THE PLACE ALONE! This is the only wild area we have left in Gorleston for our wildlife who deserve better. It saddens me to see deers and foxes forced into civilisation, scared with no where to run, or ending up dead on our roads. Have some compassion, please!

Request to be heard?: Yes

Reason for Request to be heard:I would like to hear what they have to say on the matter

Attachments: N/A

Rep ID: 395 / Respondent: Sarah Kemp

Date Received: 1/31/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB25

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Policy NAT1 and NAT4

Building 70 houses on site URB25 would have a huge negative impact on this natural woodland area. The woodland is a long-standing habitat for muntjac, foxes, rabbits and many other wildlife species. There is also an extensive range of trees, especially fruit trees like apple trees and cherry trees and a biodiversity culture of nature. To cement over this beautiful area is inhumane.

It is widely documented that the dualling of the Acle Straight has never been permitted due to an endangered species of snails. Who knows what else lies within these woodlands. This development must not be permitted to go ahead at the expense of all the Nature in the area.

Para 4.248 and Para 4.249 already highlight issues connected to this natural habitat, yet alone the Mineral Safeguarding Area.

Policy OSS1

Building 70 houses on site URB25 is completely the wrong location and strategy. This site is home to a natural wild woodland area, full of wild animals and tree species as explained above.

The woodland area is also a site of great historic interest - The East Anglian School for the blind and deaf was opened by Earl Leicester in May 1912, after 17 acres of land was gifted to Great Yarmouth Borough Council. It was the second in the country to adopt "the cottage home" principle to provide a family life for the youngsters. The school taught blind and deaf children for over 73 years and was funded by several local education authorities in East Anglia, until it became the responsibility of Norfolk County Council in 1974. It finally closed its doors in July 1985.

The site was later (wrongly) cleared to make way for new homes and the St. Mary's Catholic Primary School. The new road was named East Anglian Way. A blue plaque was placed in 2012 on the former headmaster's house on Church Road, by the Great Yarmouth History and Archaeological Society.

During the Second World War all the children and staff moved to Aberpergwm House in Glynneath, West Glamorgan Wales. Articles suggest that the military took occupation of the school in 1940 and in 1941, the school grounds and headmaster's house suffered severe damage, the house was rebuilt again by 1945 - A large bomb crater can also still be seen within the old grounds, which is now part of the woodland.

In the pre-submission plans (Page 97, Section 4.246), it details significant World War II remains that have previously existed, including balloon barrage sites and weapon pits and the need for an archaeological assessment to understand the significance of any potential archaeological remains on the site.

This historic site should therefore be preserved, and it is fitting with its history that nature can continue to claim the land. The natural woodland is used daily by families who enjoy this peaceful habitat, walk their dogs and by nature enthusiasts. I cannot comprehend why anyone would want to cement over this site of natural beauty.

Policy OSS3

To build 70 houses on site URB25 would be a direct violation of policy 0SS3. This site is a natural woodland and habitat for muntjac, foxes, rabbits and many more visible and camouflaged wildlife. Within these natural woodlands also lies a biodiversity culture of nature and to cement over this would be inhumane. Building just one house on this natural woodland area would be a direct violation of OSS3 (b) a forestry development of nature's own making. The housing development must not go ahead.

Policy OSS4

In addition to the devastating impact building 70 homes on site URB25 would have on nature, the infrastructure itself is not in place to support all these new homes.

Para 4.245 and 4.257 highlights the issues of flooding (Flood Risk Zone A) and drainage and how a strategy would need to be developed to accommodate this. The infrastructure is not in place to support this, yet alone the drainage. Great Yarmouth already suffers with drainage issues and there are regular reports of sewerage flowing onto Gorleston Beach. This new housing development would compact the existing issue with drainage, making a bad matter even worse.

GP services in the area are already saturated and cannot cope with the demands and pressures being put on them currently.

The Beaches Doctor's surgery is the only Doctor's in Gorleston, which is already oversubscribed.

Millwood Surgery in Bradwell already cannot cope due to c.800 houses being built and not one extra GP being added to the area.

Doctors surgeries In Gt Yarmouth (Park Surgery) are redrawing their catchment area, removing residents of Bradwell from their list as they are oversubscribed.

There is no NHS Dentist in Gorleston, the nearest being Bradwell and Great Yarmouth.

The roads around East Anglian way cannot cope around the times of the school run as they are. Bottlenecks occur regularly, and the narrow roads are not wide enough for cars to get past, yet alone turn round. Emergency services would never get past in an emergency situation at certain times of the day.

To cement over the woodland and kill the wonderful nature it holds, doesn't make any sense when you have all the above issues already in place. Just getting into or out of the area at certain times of the day is going to be impossible.

Suggested Modifications: Site URB25 should simply not be built on. The area should be a protected woodland where nature and its wildlife can thrive. The council won't have to spend so much of tax payers money on biodiversity and nature conservation if it stopped ripping up our natural woodland spaces. It makes no sense.

Policy NAT1 and NAT4

Building 70 houses on site URB25 would have a huge negative impact on this natural woodland area. The woodland has a long-standing habitat of muntjac, foxes, rabbits and many other wildlife species as well as an extensive range of trees and other plant life. To cement over this beautiful area is inhumane.

Policy OSS1

The beautiful nature and wildlife of site URB25 should be protected and left alone. It is also a site of great historic interest as mentioned in the section above which should be honoured and not bulldozed over for more housing.

Policy OSS3

To build 70 houses on site URB25 would be a direct violation of policy 0SS3. This site is a natural woodland and habitat for muntjac, foxes, rabbits and many other species. Building just one house on this natural woodland area would be a direct violation of OSS3 (b) a forestry development of nature's own making. The housing development must not go ahead.

Policy OSS4

The infrastructure is not in place to support 70 new homes on site URB25. Gorleston already has enough issues with regards to flooding, drainage, lack of GPs and dentist and also the roads around East Anglian way which the new houses would rely on just wont be able to cope. They get bottlenecked daily currently during the school run hours. Getting in or out around there at those times would be near impossible. Imagine a medical emergency or fire in one of the new houses you want to build. Trying to get emergency services to those houses during the school run times would be chaos and the danger of loss of lives would be high.

Please protect site URB25 and let it be a safe haven to all the wildlife in the area. Please don't destroy it for more housing that the area won't be able to cope with.

Request to be heard?: No

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 396 / Respondent: Andrew Baker

Date Received: 1/31/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB25 4.24

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Does not comply with Duty to Co-operate

Reasons: Hi,

Duty to co-operate :- I live adjacent to the proposed site and have not been consulted about the proposed building plan at all. It was only a friend in Bradwell that happened to see that there was a meeting concerning the Local Plan that alerted me to the proposed use of the site.

Unsound and not legally compliant: In 2019 the planning inspectorate rejected the appeal to build on the land behind East Anglian Way and ruled that the building plan proposed did "not provide sufficient assurance that the proposal would not result in unacceptable levels of congestion.

As a result, the proposal would be likely to result in regular inconvenience to users of the highway.

The development would consequently have a harmful effect on the convenient use of the highway network.

The proposal would result in a significant increase in vehicular movements along East Anglian Way, coupled with the potential for conflict between vehicles and more vulnerable road users due to congestion and manoeuvring.

It would consequently increase the potential for accidents, with resulting harm to highway safety,"

Concluding remarks noted the "adverse impacts of granting permission would significantly and demonstrably outweigh the benefits.

Therefore the proposal would not be a sustainable form of development,"

The local plan wants to use exactly the same access off East Anglian Way that has already been rejected by the planning inspectorate. Paragraph 4.241 states "Vehicular access to the site is proposed to be taken off East Anglian Way ". East Anglian Way has not changed at all since 2019 and if anything, traffic congestion has got even worse. It's also just not feasible that the tiny cul de sac on East Anglian Way can be used as access for a development of 70 houses. The road is just not big enough.

Suggested Modifications: East Anglian Way is not viable as an access route to the land proposed for development. An alternative access plan for the land behind East Anglian needs to be worked out as the current plan does not address any of the concerns the planning inspectorate had in 2019.

Request to be heard?: Yes

Reason for Request to be heard:As a resident of East Anglian Way I think it's imperative that local residents are heard.

Attachments: N/A

Rep ID: 397 / Respondent: Caister Parish Council Karina Green

Date Received: 1/31/2025

Section of the Plan: 5

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy CAS1

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Not Legally Compliant/Does not comply with Duty to Co-operate

Reasons: Caister Parish Council have summarised their feedback on the Local Plan as set out below.

Public Consultation

•Despite numerous requests and considering Caister is set to be affected by the largest amount of development, a consultation held in Caister was refused. The Parish Council offered a venue we had used previously that was extremely well attended.

•The public consultation held in Scratby most recently was poorly advertised and poorly attended.

•A senior representative advised the Chair of Caister Parish Council that whatever was said at the 'consultation' wouldn't matter as it had all been signed off last year anyway.

Online Consultation

•Confusing, daunting, overly complex

•The online process is complicated for someone skilled on a computer let alone a large proportion of residents in Caister who are not or do not have access.

•It begins by asking you to reference the particular policy, paragraph or policies map you are referring to - despite endless searching we failed to find the specific information required here.

•Some residents advised they attempted to comment online but were unable to do so due to it's complexity.

Infrastructure

•Despite how the Local Plan suggests things such as schools and medical centres are going to be provided, the reality is that the only obligation is to set land aside for such amenities

•Our services struggle to meet demand based on current population without adding a further 5000 people living on our boundary

•Quality of life will be affected - there is no doubt

•Doctors surgeries, including two not fit for purpose, are already stretched beyond comprehension with people waiting weeks upon weeks for an appointment

•Apart from misleading claims for a new medical centre to be built, where will the medical staff come from to staff it even if it is built - another very current and topical issue we are struggling with her and now with our current population

•We have two chemists in the village - both struggling - frequent closures last year due to the lack of pharmacists who were having to spread themselves so far and wide, villages were left without a local option.

•The Local Plan refers to a vague promise of land set aside for a Primary School but no plans to develop that further. In other areas of development similar to that proposed within the Local Plan, this has not always materialised and we are far from confident that it will happen here. Our understanding is that after a certain timeframe, if nobody comes forward to build the infrastructure the land is set aside for, the land returns to the developer and more houses can be built.

•Even if a Primary School is built, at some stage the older children will have to travel to schools within Caister adding to the already present parking/traffic issues faced during school run times. This will lead to additional traffic along Prince of Wales Road and Norwich Road already the busiest, fastest road in Caister. In turn, more traffic leads to poorer air quality affecting everyone.

•Caister currently has just two football pitches for a village of 9,000 and there are no plans for recreation or sporting facilities in the new development. That means in a 'village' that could house over 14,000 people they have just two football pitches. When we raised this with the planners, they had not given it any thought.

•Sewage works - The ongoing issues we have with the odour from the sewage works are still very apparent - regular contact with Anglian Water and Environmental Healh and increasing complaints from residents - how will the system cope with more pressure from more houses if it cannot cope now? Not to mention the amount of raw sewage that has been pumped into the North Sea off Caister - figures have risen every year for the past four years.

•Police - Just when you think our police force cannot be stretched anymore - we are looking to add an additional 5,000+ people into the mix. Our local Police Officer is great but he is already stretched and is often called to help in other areas leaving us without cover - we have already lost our local police station which adds to the visibility and response times.

•Highway - The Plan includes the downgrading of the Northern section of Caister bypass which will lead to slower traffic and traffic finding alternative routes through the centre of Caister, adding to congestion and poor air quality. All these things are part of infrastructure, the glue that holds things together and the oil that keeps them running

smoothly and without them, everyone's quality of life is affected.

We do understand the need for housing BUT, in order for it to work for everyone, it needs the appropriate infrastructure alongside it.

665 houses are already planned for this site and we believe that to add another 1100 is just too many without the necessary infrastructure without it affecting the quality of life of everyone.

We understand that this development would all be built by Persimmon. This brings about it's own concerns around the character of our village as 'uniform developments' begin to take over.

Caister has a proud history and has been a village for 2,000 years and we believe that other than the 'need for housing', very little thought has gone into the wider scope of this proposal including the effects on existing communities and infrastructure.

Caister Parish Council remains genuinely concerned and firmly opposed to the Local Plan as it stands without any guaranteed infrastructure.

Suggested Modifications: See Question 5

Request to be heard?: Yes

Reason for Request to be heard:As a Parish Council we have a responsibility to our Parishioners to fight for what is right for our village and we would like to be involved fully in the process to facilitate this

Attachments: REP397 - Caister Parish Council (PDF, 141 KB)(opens new window)

Rep ID: 398 / Respondent: Sports England

Date Received: 1/31/2025 4:46:00 PM

Section of the Plan: 12

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy HEC2

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: The evidence base informing this policy, includes Great Yarmouth's Playing Pitch and Outdoor Sports Strategy (2022) (PPOSS).

Paragraph 103 of the National Planning Policy Framework states that,

'Planning policies should be based on robust and up-to-date assessments of the need for open space, sport and recreation facilities (including quantitative or qualitative deficits or surpluses) and opportunities for new provision.'

Sport England's Playing Pitch Guidance at Step 10 advises that, 'as a guide, if no review and subsequent update has been carried out within three years of the PPS (playing pitch strategy) being signed off by the steering group, then Sport England and the NGBs would consider the PPS and the information on which it is based to be out of date. The nature of the supply and in particular the demand for playing pitches will likely to have changed over the three years. Therefore, without any form of review and update within this time period it would be difficult to make the case that the supply and demand information and assessment work is sufficiently robust.'

The evidence base supporting Policy HEC2 is considered to be up to date. To ensure the evidence base supporting Policy HEC2 and Appendix 3 remains up to date Sport England advises re-wording paragraph A3.6 as follow:

'Accordingly, the Open Space Needs Assessment and Playing Pitch and Outdoor Sports Strategy should be updated every 3 years'.

If a Stage E process, which includes delivering the strategy and keeping it robust and up to date (see Sport England's Playing Pitch Strategy Guidance for more detail on Stage E), is not carried out in the next year, there is a concern that following adoption of the Local Plan, decisions about planning for meeting the current and future sports facility needs of the community will not be based on an up-to-date, and therefore robust, evidence base in accordance with the requirements of paragraph 103 of the NPPF.

To address these concerns, it is requested that the Council prepares a Stage E meeting with all relevant national governing bodies of sport, and Sport England to update the content of the PPOSS. This approach would in principle allow the plan to accord with Government policy in paragraph 103 of the NPPF.

Suggested Modifications: pdate A3.6 to 'Accordingly, the Open Space Needs Assessment and Playing Pitch and Outdoor Sports Strategy should be updated every 3 years'. Concern was raised regarding the delivery of the Open Space Needs Assessment and Playing Pitch and Outdoor Sports Strategy which also require updating within the next year to ensure evidence remains up to date.

Request to be heard?: Not Specified

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 399 / Respondent: Swifts Local Network: Swifts & Planning Group Michael Priaulx

Date Received: 1/31/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT1 6.16

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Paragraph 6.16 is very welcome to implement the NPPF and NPPG and provide accurate supporting text for swift bricks, but it is it is not currently sound nor effective as there is a typo in the sentence regarding 'Hedgehog Highways', and also sparrow terraces are referenced but this is not consistent with national policy as there is evidence that these are an ineffective and inflexible choice unsuitable for other species so often left empty (e.g. see https://actionforswifts.blogspot.com/2014/11/how-to-help-house-sparrows.html?m=1 ), and they are not supported by any national planning policy or guidance or the National Model Design Code guidance or compliant with BS 42021 for Integral Nest Boxes,

whereas swift bricks are a universal nest brick used by a range of small bird species including sparrows (see NHBC Foundation: Biodiversity in New Housing Developments (April 2021) Section 8.1 Nest sites for birds, page 42: "Although targeting swifts they will also be used by house sparrows, tits and starlings so are considered a 'universal brick'"

https://www.nhbcfoundation.org/wp-content/uploads/2021/05/S067-NF89-Biodiversity-in-new-housing-developments_FINAL.pdf ), and CIEEM blog (26/07/21):

https://cieem.net/swift-bricks-the-universal-nest-brick-by-dick-newell/ ), supported by NPPG 2019 Natural Environment paragraph 023 which highlights the importance of swift bricks, and NPPF December 2024 Paragraph 187 (d) (page 54) which states "planning policies should... incorporate features which support priority or threatened species such as swifts",

so we request that to be consistent with national policy the reference to sparrow terraces is removed.

Suggested Modifications: Please correct ", connected spaces for

hedgehogs e.g. 'Hedgehog Highways' and other mammals and hibernacula."

to ", connected spaces for hedgehogs and other mammals e.g. 'Hedgehog Highways', and hibernacula."

Please delete the reference to sparrow terraces, to be consistent with national policy.

Please add "Swift bricks are a universal nest brick for cavity-nesting small bird species." for information, to be effective

Request to be heard?: Yes

Reason for Request to be heard:To provide further information, if required.

Attachments: N/A

Rep ID: 400 / Respondent: Persimmon Homes (Anglia)

Date Received: 1/31/2025

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy OSS3

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Development Limits are defined on the Policies Map. - Inclusion of allocated sites, particularly where they abut existing Development Limit boundaries, is warranted in so far as they expand existing settlements and there is no material distinction in how the allocations perform in land use terms.

Development will be supported in principle within the Development Limits subject to compliance with other relevant policies in the development plan - The purpose and function of the allocated sites is to be supportive of new policies will treat sites within Development Limits from allocated sites, with the exceptions of the requirement to provide an enhanced level of BNG.

Allocated sites, particularly large scale major developments (over 200 dwellings) will be delivering a variety of different forms of green infrastructure and strategic infrastructure which could materially impede the ability of such sites to deliver above the statutory level of BNG. Inclusion within the Development Limits will secure delivery of BNG without affecting the deliverability and potentially viability of the allocations concerned.

See attachment

Suggested Modifications: -

Request to be heard?: Yes

Reason for Request to be heard: As one of the main house builders in the Borough with interest in two of the largest allocations in the GYLP, it is important Persimmon Homes participate in hearing sessions to assist the inspector in understanding the background and contextual information associated with the site and consider any points raised in these representations.

Attachments: REP400 - Persimmon Homes (Anglia) (PDF, 241 KB)(opens new window)

Rep ID: 401 / Respondent: Persimmon Homes (Anglia)

Date Received: 1/31/2025

Section of the Plan: 3

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy OSS5

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: We commissioned Highgate Land and Development (HLD) to test the viability evidence prepared in support of the Great Yarmouth Local Plan (GLYP), which included the Local Plan Viability Assessment prepared by HDH Planning and Development, as well as the Great Yarmouth Local Plan Infrastructure Needs Study (November 2024).

A copy of this assessment is submitted in support of these representations and identifies a number of concerns in relation to the Local Plan Viability Assessment. This includes site-specific viability concerns relating to CAS1 and URB19 (see Appendix 1).

'Why should strategic sites be assessed for viability in plan making?'

It is important to consider the specific circumstances of strategic sites. Plan makers can undertake site specific viability assessment for sites that are critical to delivering the strategic priorities of the plan. This could include, for example, large sites, sites that provide a significant proportion of planned supply, sites that enable or unlock other development sites or sites within priority regeneration areas. Information from other evidence informing the plan (such as Strategic Housing Land Availability Assessments) can help inform viability assessment for strategic sites'

We contend that the specific circumstances of the strategic site have not been properly assessed with particular concerns relating to site-specific infrastructure costs and abnormal development costs.

Paragraph 3.25 of the GYLP explains that development allocated by Policy CAS1 will contribute towards infrastructure provision through section 106 contributions as this allows for more flexibility in phasing of payments and therefore potentially allows for greater sums to be secured than would otherwise be possible through CIL. Given this is the approach taken by GYC we would have expected additional viability evidence would have been prepared on this basis in line with HDH recommendations. There is no evidence that viability has been assessed on this basis.

Additionally, HDH highlight that the delivery of large strategic sites is challenging and recommend Council's engage with landowners to understand site-specific delivery issues in line with national guidance. No contact has been made since the production of HDH's report.

As currently drafted Policy OSS5 only allows development viability to be considered at the planning application stage based on reaching a threshold in developer contributions. We would suggest this approach is not consistent with paragraph 59 of the NPPF which states:

'It is up to the applicant to demonstrate whether particular circumstances justify the need for a viability assessment at the application stage. The weight to be given to a viability assessment is a matter for the decision maker, having regard to all the circumstances in the case, including whether the plan and the viability evidence underpinning it is up to date, and any change in site circumstances since the plan was brought into force. All viability assessments, including any undertaken at the plan-making stage, should reflect the recommended approach in national planning practice guidance, including standardised inputs, and should be made publicly available.' Nor is it consistent with guidance at Paragraph: 007 Reference ID: 10-007-20190509 of the PPG.

Part a) of the policy should be removed to ensure the deliverability of sites across the local plan and consistency with nation policy and guidance.

We consider the wording of this policy to be extremely inflexible (with regards to both URB19 and CAS1, as well as other sites/typologies) and we would expect to see a broader range of reasons to be considered with regards to the development viability at the decision taking state (particularly for strategic sites given the high-level assumptions applied). In our experience, we have not encountered any other Local Plans that have aimed to restrict the basis for a viability assessment at Planning Application stage in this way. The inflexible nature of this policy calls into question the delivery of the plan (given the high-level nature of the study, particularly with regards to the strategic sites) and is also at offs with the PPG.

Suggested Modifications: We recommend that this policy builds in additional flexibility to ensure viability

can be considered more broadly at planning application stage (if required) for

all sites, rather than restricting it based on a threshold for planning obligations,

in addition to affordable housing and CIL (where applicable). Flexibility in this

policy will help to ensure that such policies are realistic and will not undermine

the delivery of the plan, as set out in Paragraph 002 of the PPG and paragraphs

16(b), 36(c), 35, and 59 of the NPPF.

Request to be heard?: Yes

Attachments: REP401 - Persimmon Homes (Anglia) (PDF, 5 MB)(opens new window)

Rep ID: 402 / Respondent: Persimmon Homes (Anglia)

Date Received: 1/31/2025

Section of the Plan: 16

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy NAT3

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Similar to the Home Builders Federation's response to the Regulation 18 First Draft Local Plan consultation, we believe that all development proposals within the Borough to require 20% biodiversity net gain (BNG) is unjustifiable. It is unnecessary to seek a higher percentage of biodiversity net gain, above the statutory requirements. The Local Plan Viability Assessment has assumed 'negligible' costs for providing BNG on-site, and this view is over-simplified. We have provided further comment under Policy OSS5 - Development Viability. We believe that the provision of formal open space along with enhanced BNG provision on allocated sites requiring 20% BNG can impact the deliverability of a site. Large scale major developments (over 200 dwellings) will be delivering strategic infrastructure, the requirement to provide BNG above the statutory level which could affect the deliverability and viability of the sites. This has not been tested.

The proposed allocations of URB19 and CAS1 will cumulatively bring 1400 houses to the Borough. As set out in our representation on draft Policy OSS3, the location of these sites abutting existing settlements means that statutory BNG is appropriate, and any further uplift in BNG provision is unreasonable in light of other environmental and social infrastructure requirements arising from these allocations.

This requirement could potentially be prohibitive and affect on site delivery of viable, Policy compliant schemes.

Suggested Modifications: -

Request to be heard?: Yes

Attachments: REP402 - Persimmon Homes (Anglia) (PDF, 260 KB)(opens new window)

Rep ID: 403 / Respondent: Persimmon Homes (Anglia)

Date Received: 1/31/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB19

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: We note the allocation is for 300 homes and support the Council in bringing this allocation forward

Criteria a) - Noted.

Criteria b) - The requirements of this part of the policy are potentially restrictive and we would request flexibility is incorporated to account for site specific circumstances.

Criteria c) - We note C. i), and under the Regulation 18 stage of the consultation, we provided a response detailing the inclusion of a 7.5 tonne weight limit on the proposed vehicular through-route to URB20.

We acknowledge the Council's response to the consultation comments received under Regulation 18. The Council does not believe a weight restriction is necessary, considering the alternative routes proposed to the employment land from the south via Gawain Road into the existing business park. Therefore, we seek certainty that the northern parcel of URB20 is limited to Use Class B1 (office use) only, to reduce likelihood of HGV movements through URB19, to protect the amenity of future residential occupiers.

We have made representations in relation to Policy URB20 to state our case as above.

We note the Council's response to our concerns regarding C. ii) and accept the provision of a 3.0m footway/cycleway along the frontage of Beaufort Way to the Beaufort Way/Gorleston Lane roundabout.

Criteria d) - Whilst we have no objection to providing the appropriate levels of recreational open space, play, and natural green space on site, clarity is sought regarding capacity to provide on-site outdoor sports provision and the enhanced BNG provision referenced under part f) of this policy. The combined requirements could impact on the viability and deliverability of this development. On this basis, separate representations have been made in relation to Policy OSS3 and NAT3.

Criteria d) - i) We note the changes made from the previous iteration of the Policy with the insertion of 'an appropriate woodland buffer' along the western boundary of this allocation. We have no objection in principle, noting that is has been incorporated to alleviate concerns raised during the Regulation 18 Consultation regarding the loss of woodland associated with URB20.

ii) Whilst we have no objection in principle to the provision of a buffer, we have been advised by the landowner that there is no certainty regarding the delivery of the northern section of the URB20 allocation, and on this basis look to understand the rationale and function for the southern buffer within URB19, beyond good landscape design principles.

Criteria f) - Policy NAT 3 requires all major development proposals to deliver at least 20% measurable biodiversity net gain attributable to the development.

Representations are made in relation to this policy separately as we have concerns regarding the ability of the site to be able to accommodate the needs set out in Part d) of this policy and achieve the proposed non-statutory BNG quantum arising from the requirements of complying with NAT3.

As stated above, in relation to Part d), concerns emanate from being able to secure sufficient on-site provision, when considered in combination with other green infrastructure requirements, and the resulting impacts this would have on achieving a viable, development on this site. As stated above, there are concerns relating to infrastructure requirements and representations have been made on Policies NAT3, OSS3, and OSS5 in this regard.

Crtieria g) - Noted.

Suggested Modifications: -

Request to be heard?: Yes

Attachments: REP403 - Persimmon Homes (Anglia) (PDF, 270 KB)(opens new window)

Rep ID: 404 / Respondent: Persimmon Homes (Anglia)

Date Received: 1/31/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB20

Sound/Legally Compliant/Duty to Co-operate Response:Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Under the Use Classes Order, Use Classes E - Commercial, Business, and Services is as follows:

i) office

ii) the research and development of products or processes or

iii) any industrial process, (which can be carried out in any residential area without causing detriment to the amenity of the area by reason of noise, vibration, smell, fumes, smoke, soot, ash, dust or grit).

We note that under Class E, industrial processes that do not cause detriment to the amenity of the area are permitted. Notwithstanding, we seek an additional limitation to office and research and development uses only on the northern sector of the allocation with the specific purpose of reducing the

likelihood of HGV movements through URB19.

We query the requirement of two parcels of land that is allocated within URB20 to be provided as the Business Park Allocation, and what level of support or engagement was sought from the landowner regarding the provision of two parcels of land within the URB20 allocation. While we understand that both parcels of the land would be beneficial for the economic growth within the Borough, we seek clarity on the deliverability of the northern parcel of land, directly south of URB19.

In the event that the allocation remains as currently drafted, we seek confirmation that the northern parcel within the employment land allocation, closest to the URB19 residential allocation, is limited to use class B1 a) as an office only. We are keen to see this parcel of land be permitted for only office uses, and not warehouse uses. This is to limit the number of HGV movements that would go to the northern parcel of the employment land allocation via Beaufort Way and through the residential allocation of URB19.

Should warehouse uses be permitted, we seek confirmation that this would be located on the southern parcel of the employment land, with access to this area via Gawain Road only for HGVs

Noted, though we believe this should be further differentiated between the northern parcel of the site and the southern parcel of the employment land allocation.

Assuming the allocation remains as currently drafted, should warehouse uses be permitted on this site (via Use Class B8), we believe that HGV movement into this area be restricted to access via Gawain Road only.

Suggested Modifications: -

Request to be heard?: Yes

Attachments: REP404 - Persimmon Homes (Anglia) (PDF, 233 KB)(opens new window)

Rep ID: 405 / Respondent: About Blooming Thyme - Jessica Rodgers

Date Received: 1/31/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB25

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Policy NAT1

The woodland plays a vital part in the ecological landscape, thriving with all kinds of nature and has a large variety of established plants; comprising of trees, shrubs, forest floor plants and wild meadows.

Not only this but, fruiting plants also resides within the woodland including apple trees, cherry trees, gooseberry bushes and blackberries to name a few.

This natural woodland is also host to a large biodiversity culture of mother nature, to cement over this would not only be totally unethical and irresponsible but, it would be completely inhumane.

It is widely documented and well-known within the area, that the dualling of the Acle straight has never been permitted due to an endangered species of snails. Who knows what else lays within natures back garden of this natural woodlands.

This development should not be permitted to go ahead at the expense of Mother Nature's own wild free back garden and must be protected.

Policy NAT4

Not only this but, fruiting plants also resides within the woodland including apple trees, cherry trees, gooseberry bushes and blackberries to name a few.

This natural woodland is also host to a large biodiversity culture of mother nature, to cement over this would not only be totally unethical and irresponsible but, it would be completely inhumane.

This development should not be permitted to go ahead at the expense of Mother Nature's own wild free back garden and must be protected.

Para 4.248 and Para 4.249

Para 4.248 and Para 4.249 already highlights the issues connected to this natural habitat for Mother Nature, yet alone mineral safeguarding.

Why can't nature be left as it is? It should not be messed with, nor should we be building in Mother Nature's back garden.

Policy OSS1

Building 70 houses on site URB25 is completely is the completely wrong location and strategy. This site is home to a natural wild woodland area, which is habitat to Mother Nature. I have set out in greater detail on NAT1 (copied below) why this location is wrong.

Not only this but, fruiting plants also resides within the woodland including apple trees, cherry trees, gooseberry bushes and blackberries to name a few.

This natural woodland is also host to a large biodiversity culture of mother nature, to cement over this would not only be totally unethical and irresponsible but, it would be completely inhumane.

The location is wrong for so many reasons. This development should not be permitted to go ahead at the expense of Mother Nature's own wild free back garden and must be protected.

With a surface water flow path existing and the need for the site to be supported by a site-specific flood risk assessment, highlights the importance of woodlands and how they act as a vital form of protection to residential areas from flood risks. Cementing over this would not only be reckless, but completely ill-considered.

Furthermore, this last piece of remaining woodland area is a site of great historical interest - The school was opened by Earl Leicester in May 1912, after 17 acres of land was gifted to Great Yarmouth Borough Council. It was the second in the country to adopt "the cottage home" principle to provide a family life for the youngsters.

The school taught blind and deaf children for over for 73 years and was funded by several local education authorities in East Anglia, until it became the responsibility of Norfolk County Council in 1974. The school taught blind and deaf children for over for 73 years, until it finally closed its doors in July 1985.

During the Second World War all the children and staff moved to Aberpergwm House in Glynneath, West Glamorgan Wales. Articles Suggest that military took occupation of the school in 1940 and in 1941, the school grounds and headmaster's house suffered severe damage, the house was rebuilt again by 1945 - A large bomb crater can also still be seen within the old grounds, which is now part of the woodland.

This historical site should therefore be preserved, and it is fitting with its history that Mother Nature herself sits on guard over this.

Policy OSS3

Not only this but, fruiting plants also resides within the woodland including apple trees, cherry trees, gooseberry bushes and blackberries to name a few.

This natural woodland is also host to a large biodiversity culture of mother nature, to cement over this would not only be totally unethical and irresponsible but, it would be completely inhumane.

This development should not be permitted to go ahead at the expense of Mother Nature's own wild free back garden and must be protected.

Building just one house on this natural woodland area would be a direct violation of (OSS3 (b) - A forestry development of Mother Nature's own making.

This development MUST NOT go ahead.

Policy OSS4

In addition to the unspeakable impacts building 70 houses on the site URB25 would have on Mother Nature herself, the infrastructure itself is not in the place to support this.

Para 4.245 and 4.257 highlights the issues and flooding (Flood Risk Zone 1) and drainage and how a strategy would need to be developed to accommodate. It is evident that the infrastructure is not in the place to support this scheme, yet alone drainage. Great Yarmouth and Gorleston already suffers with drainage issues and it is regularly reported of sewerage flowing onto Gorleston Beach. I highly suggest this housing development would compact the existing issue with drainage, making a bad situation worse.

The Beaches Doctor's Surgery is the only doctors in Gorleston, which is already struggling and oversubscribed.

Millwood Surgery in Bradwell already cannot cope due to 800 houses being built and not one extra GP being added to the area.

Doctor's surgeries in Great Yarmouth (Park Surgery) are redrawing their catchment area, removing residents of Bradwell from their lost as they are oversubscribed. Issues in Doctors surgeries are coming to a head - this service is saturated and cannot cope with the demands and pressures being put on them.

There is no NHS Dentist in Gorleston, the nearest being Bradwell and Great Yarmouth.

The roads around east Anglian Way already cannot cope around the times of the school run, bottlenecks occur regularly, and the narrow roads are not wide enough for cars to get past, yet alone turn around. The emergency services would never get past in an emergency situation at certain times of the day. Do we actually want more tarmac? No, not in Mother Nature's back yard!

Suggested Modifications: This plan should not go ahead and the land should be turned into a Nature Reserve, to conserve for many generations after us.

The growth outlined in this Local Plan is NOT supported by the necessary infrastructure needed to support and service the proposed development; but instead adds extra pressure on existing infrastructures.

The plan is completely unsustainable and can have a significant effect on the capacity of existing infrastructure, and therefore creates potential risks to the economy, or society which cannot be mitigated.

By protecting the woodlands as a Nature Reserve, it can ease pressures of existing infrastructures and reduce risks to the environment and economy.

Not only this but, the land is sensitive to a range of impacts associated with development including habitat loss, light or noise, air pollution, recreation pressure and disturbance, pollution, changes in water levels and loss of biodiversity & geodiversity.

In order to promote habitats, improve biodiversity and reduce pollution, the woodlands must be taken over as a Nature Reserve and implement a sustainable pattern of development, to improve the environment and mitigate climate change.

The woodland is an area of high biodiversity value and provides an essential natural habitat to a large variety of wildlife. By turning the site in to a Nature Reserve, it can continue to promote habitats, improve biodiversity, reduce pollution and improve air quality.

Due to the volume of houses on such a small piece of land, the proposed plans do not secure any open spaces and creates many potential risks to the environment. With the sheer lack of natural green-spaces in the town already, this woodland plays a vital role within the community; especially with so many established plants and thriving wildlife.

This plan for 70 houses is set in the wrong location entirely and can have adverse effects on the integrity of the habitat and should not be built on. There are a number of brownfield sites and derelict buildings in the area, that can be utilized far better than our local woodland that hosts much wildlife.

Furthermore, the woodlands have a rich and colourful history, that makes the preservation of this land crucial and does not deserve to be cemented over.

The proposed plans do not help maintain, restore or enhance the natural landscape, nor does it encourage or promote forestry, or sustainable developments within the area; it just ruins it.

Building on this land can have adverse effects on the integrity of the habitat and should therefore not be built on. The plans do not have any positive contributions towards biodiversity and/or geodiversity in the area. By preserving the woodlands as a Nature Reserve, an increased protection can be given to a variety of wild animals, plants and habitats; this is a vital part of national and global efforts to conserve biodiversity.

As a result, any adverse impacts on existing biodiversity and geodiversity assets can be avoided and the woodland can continue to be a wildlife corridor and habitat 'stepping stone'.

The proposed plans do not help improve the quality of the built environment, nor does it help improve ecological characteristics or maintain the open and rural character. By protecting the site as a Nature Reserve, it can continue to improve the quality of the built environment, mitigate climate change and promote a conservation.

I do not support this plan!

Request to be heard?: Yes

Reason for Request to be heard:I have played a vital part in the community to gain objections and feel like it is my place to participate in the hearing, not only for myself, but for representation for those that can not make it.

Attachments: N/A

Rep ID: 406 / Respondent: Ian Allen

Date Received: 1/31/2025

Section of the Plan: 4

Paragraph / Policy / Figure / Table Rep / Appendix / Evidence:Policy URB25

Sound/Legally Compliant/Duty to Co-operate Response:Not Sound/Legally Compliant/Complies with Duty to Co-operate

Reasons: Policy NAT1

Not only this but, fruiting plants also resides within the woodland including apple trees, cherry trees, gooseberry bushes and blackberries to name a few.

This natural woodland is also host to a large biodiversity culture of mother nature, to cement over this would not only be totally unethical and irresponsible but, it would be completely inhumane.

This development should not be permitted to go ahead at the expense of Mother Nature's own wild free back garden and must be protected.

Policy NAT4

Not only this but, fruiting plants also resides within the woodland including apple trees, cherry trees, gooseberry bushes and blackberries to name a few.

This natural woodland is also host to a large biodiversity culture of mother nature, to cement over this would not only be totally unethical and irresponsible but, it would be completely inhumane.

This development should not be permitted to go ahead at the expense of Mother Nature's own wild free back garden and must be protected.

Para 4.248 and Para 4.249

Para 4.248 and Para 4.249 already highlights the issues connected to this natural habitat for Mother Nature, yet alone mineral safeguarding.

Why can't nature be left as it is? It should not be messed with, nor should we be building in Mother Nature's back garden.

Policy OSS1

Not only this but, fruiting plants also resides within the woodland including apple trees, cherry trees, gooseberry bushes and blackberries to name a few.

This natural woodland is also host to a large biodiversity culture of mother nature, to cement over this would not only be totally unethical and irresponsible but, it would be completely inhumane.

The location is wrong for so many reasons. This development should not be permitted to go ahead at the expense of Mother Nature's own wild free back garden and must be protected.

This historical site should therefore be preserved, and it is fitting with its history that Mother Nature herself sits on guard over this.

Policy OSS3

Not only this but, fruiting plants also resides within the woodland including apple trees, cherry trees, gooseberry bushes and blackberries to name a few.

This natural woodland is also host to a large biodiversity culture of mother nature, to cement over this would not only be totally unethical and irresponsible but, it would be completely inhumane.

This development should not be permitted to go ahead at the expense of Mother Nature's own wild free back garden and must be protected.

Building just one house on this natural woodland area would be a direct violation of (OSS3 (b) - A forestry development of Mother Nature's own making.

This development MUST NOT go ahead.

Policy OSS4

In addition to the unspeakable impacts building 70 houses on the site URB25 would have on Mother Nature herself, the infrastructure itself is not in the place to support this.

The Beaches Doctor's Surgery is the only doctors in Gorleston, which is already struggling and oversubscribed.

Millwood Surgery in Bradwell already cannot cope due to 800 houses being built and not one extra GP being added to the area.

There is no NHS Dentist in Gorleston, the nearest being Bradwell and Great Yarmouth.

Suggested Modifications: This plan should not go ahead and the land should be turned into a Nature Reserve, to conserve for many generations after us.

By protecting the woodlands as a Nature Reserve, it can ease pressures of existing infrastructures and reduce risks to the environment and economy.

This plan for 70 houses is set in the wrong location entirely and can have adverse effects on the integrity of the habitat and should not be built on and does not meet the requirements of policy OSS1, OSS3, NAT4 & NAT1. There are a number of brownfield sites and derelict buildings in the area, that can be utilized far better than our local woodland that hosts much wildlife.

Furthermore, the woodlands have a rich and colourful history, that makes the preservation of this land crucial and does not deserve to be cemented over.

The proposed plans do not help maintain, restore or enhance the natural landscape, nor does it encourage or promote forestry, or sustainable developments within the area; it just ruins it.

By preserving the woodlands as a Nature Reserve, an increased protection can be given to a variety of wild animals, plants and habitats; this is a vital part of national and global efforts to conserve biodiversity.

As a result, any adverse impacts on existing biodiversity and geodiversity assets can be avoided and the woodland can continue to be a wildlife corridor and habitat 'stepping stone'.

The proposed plans do not help improve the quality of the built environment, nor does it help improve ecological characteristics or maintain the open and rural character and does not meet the requirements of policy OSS4. By protecting the site as a Nature Reserve, it can continue to improve the quality of the built environment, mitigate climate change and promote a conservation. I do not support this plan!

Request to be heard?: No

Reason for Request to be heard:-

Attachments: N/A

Rep ID: 407 / Respondent: Gary Shane Rodgers