Support

Representation ID: 3942

Received: 05/09/2024

Respondent: NHS Norfolk and Waveney Integrated Care System

There are 4 villages whereby the most local GP practice that covers those villages within its catchment area is located across the local authority border in East Suffolk. Two GP practices will be affected by any population increases. These practices are either currently working through a planning application for an extension funded by CIL or are in early discussions about a potential premises scheme via a potential application for CIL funding.

The ambulance service, EEAST, are in a unique position that intersects health, transport and community safety and does not have capacity to accommodate the additional growth resulting from the proposed development combined with other developments in the vicinity. This development is likely to increase demand upon existing constrained ambulance services and nationally set blue light response times. The capital required through developer contribution would form a proportion of the required funding for the provision of capacity to absorb the patient growth and demand generated by this development. Any funding would be used towards the capital cost of providing new additional ambulances and/or new additional medical equipment, which for an ambulance service is their physical infrastructure, and/or new additional parking space(s) for ambulances at existing ambulance stations.

Support

Representation ID: 3960

Received: 26/09/2024

Respondent: Norfolk Wildlife Trust

We are pleased to note that this policy includes a specification for the retention, protection and enhancement of the existing vegetation and trees

Object

Representation ID: 3983

Received: 26/09/2024

Respondent: Norfolk County Council - Minerals and Waste Team

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Norfolk County Council in its capacity as the Mineral Planning Authority considers that Policy VC EAR2 is currently unsound; as it is inconsistent with national policy (NPPF paragraph 218), and the adopted Development Plan in Norfolk (policy CS16 of the Norfolk Minerals and Waste Core Strategy), in relation to mineral resource safeguarding.

The proposed site allocation VC EAR2, is located within the consultation area for safeguarded mineral extraction site, Earsham Quarry, which is only 25m from the boundary of site VC EAR2 at the closest point, with the A143 in between. The quarry has permission for mineral extraction and processing until 2040. There is currently no reference to this in either the site assessment or the site policy.

Proposed allocation site VC EAR2 also underlain by a safeguarded mineral resource, sand and gravel. However, as the site is less than 2 hectares in size, we do not consider that a policy requirement regarding investigation and prior extraction of mineral on the allocation site is necessary.

However, the allocation of the site for development without policy requirements to protect the existing mineral extraction operation is not consistent with national policy. The agent of change principle (paragraph 193 of the NPPF) would also apply.

We consider that it is appropriate and relevant for the requirements of a strategic policy (in this case Policy CS16 of the Norfolk Minerals and Waste Core Strategy) to be included in a site allocation policy where it sets out how the policy will apply to a specific site at the development management stage.

Object

Representation ID: 3989

Received: 30/09/2024

Respondent: Historic England

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

We welcome the preparation of the HIA. The HIA recommends that archaeological investigation should be required prior to development commencing. The recommendations of the HIA in relation to archaeology should be included in the policy requirements.

The current reference to archaeology at criterion 6 is insufficient. We suggest that the wording is slightly amended to read:

Norfolk’s Historic Environment Service is consulted prior to application to determine the need for any archaeological assessments.

Support

Representation ID: 4021

Received: 03/10/2024

Respondent: Badger Building

Additional information is also attached by way of demonstrating that the frontage footpath and connection of the footpath to the existing can be delivered within the highway boundary and land owned by the County. I have attached the highway boundary maps and an overlay of the footpath onto the highways boundary to show the works are deliverable. There is also a triangular wooded area adjacent to the site that may require some trees/hedgerow cut back to facilitate the footpath. The title for this area is attached showing its owned by the County Council.

Intend to submit a planning application for the site once the allocation is confirmed following undertaking all necessary supporting reports, surveys and design.

Once permission is granted we would look to be starting on site within 18 months. The delivery of the site should be two years from start.

Support

Representation ID: 4111

Received: 02/10/2024

Respondent: Water Management Alliance

Major development - If surface water discharges within the watershed catchment of the Board's IDD, we request that this discharge is facilitated in line with the Non-statutory technical standards for sustainable drainage systems (SuDS).

Object

Representation ID: 4125

Received: 07/10/2024

Respondent: Rainier Developments and Strategic Land

Agent: Ceres Property

Legally compliant? No

Sound? No

Duty to co-operate? No

We note the objection from Norfolk County Council in its capacity as the Mineral Planning Authority (representation ID 3989). The County Council notes this proposed allocation is located within the consultation area for the safeguarded mineral extraction site (Earsham Quarry), that this quarry is on 25m from the boundary of the proposed allocation, and that it has permission for mineral extraction and processing until 2040.

The County Council requests additional policy text that includes a requirement that the development of the site “must not prevent or prejudice the use of the existing mineral extraction site unless suitable alternative provision is made, or the applicant demonstrates that the site no longer meets the needs of the aggregate industry”.

However, it is not clear from the Regulation 19 Addendum if development of the site as the current draft policy envisages and incorporating the requisite mitigation is deliverable.

Additionally, it is not clear what the impact of the existing quarry on the amenity of future occupiers of the proposed allocation would be, or whether this would be acceptable.

Support

Representation ID: 4137

Received: 07/10/2024

Respondent: Environment Agency

Current data shows limited capacity at Earsham WRC. While there may be some room for limited growth, the proposed allocations and resulting increase in foul water flows pose the potential risk of harm to the waterbody receiving treated effluent from Earsham WRC.
We therefore recommend including within policies VC EAR1 and VC EAR2 the requirement for developers of the site to enter into early engagement with Anglian Water in order to demonstrate there is sufficient capacity in the network and receiving WRC to accommodate foul flows from the development.

Object

Representation ID: 4168

Received: 07/10/2024

Respondent: Rainier Developments and Strategic Land

Agent: Ceres Property

Legally compliant? No

Sound? No

Duty to co-operate? No

We note the objection from Norfolk County Council in its capacity as the Mineral Planning Authority (representation ID 3989). The County Council notes this proposed allocation is located within the consultation area for the safeguarded mineral extraction site (Earsham Quarry), that this quarry is on 25m from the boundary of the proposed allocation, and that it has permission for mineral extraction and processing until 2040.

The County Council requests additional policy text that includes a requirement that the development of the site “must not prevent or prejudice the use of the existing mineral extraction site unless suitable alternative provision is made, or the applicant demonstrates that the site no longer meets the needs of the aggregate industry”.

However, it is not clear from the Regulation 19 Addendum if development of the site as the current draft policy envisages and incorporating the requisite mitigation is deliverable.

Additionally, it is not clear what the impact of the existing quarry on the amenity of future occupiers of the proposed allocation would be, or whether this would be acceptable.

Support

Representation ID: 4175

Received: 07/10/2024

Respondent: Anglian Water Services

The site is on the edge of the Earsham-Bungay Road WRC. There is capacity for the proposed level of growth as there is sufficient dry weather flow headroom available at the WRC. The developer would need to engage with Anglian Water regarding connections for water supply and wastewater in the usual way.

We support the need for a site-specific flood risk assessment because of the identified groundwater flood risk. Groundwater flooding and elevated water table levels can inundate our underground infrastructure and result in sewer flooding and loss of service for some properties/communities in periods of prolonged/intensive rainfall. Unfortunately, there is a lack of legislation that governs this type of scenario (where high groundwater levels impact sewerage assets, but do not cause an ‘above ground’ flood), and so we have held multiple workshops and discussions with Norfolk Strategic Flood Alliance partner organisations, in particular the Environment Agency, about managing groundwater differently in the future. Ensuring that new development is resilient to all forms of flood risk is therefore critical, and flood risk is managed appropriately to minimise cumulative impacts including on our existing and new infrastructure networks.

Object

Representation ID: 4195

Received: 13/09/2024

Respondent: Broads Authority

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Light pollution
Most of the proposed sites are on the edge of settlements. Particular care and attention need to be given to any proposals for external lighting as well as any design that has a lot of glazing. Lighting in such edge of settlement areas needs to be fully justified, serve a specific purpose, be of the right design and intensity so as to not affect dark skies, such as the intrinsic dark skies of the Broads. Reference to lighting being only needed if fully justified and well designed needs to be made in relevant policies, especially the following as they are close to, albeit separated from, the Broads. Also, design with lots of glazing need to be avoided unless there is going to be automated shades incorporated into the design.