Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum
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Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum
Policy VC SPO1REV: Land west of Bunwell Road
Representation ID: 4022
Received: 03/10/2024
Respondent: Network Rail Ltd
Legally compliant? No
Sound? No
Duty to co-operate? No
NR has provided both important general and site-specific comments on the South Norfolk Village Clusters Housing Allocations Plan – Regulation 19 Pre-submission Addendum.
For future development schemes in the South Norfolk area, NR requires that if any new infrastructure requirements affect NR and the operational railway then the appropriate agreements must be entered into by the promotors.
NR has a key requirement to manage risk appropriately for all rail infrastructure on safety grounds, to reduce risk so that it is as low as reasonably practicable. NR also requests that any developer and other key stakeholders engage with us early to discuss opportunities and enter into the necessary agreements.
Nearby Level Crossing(s), including Spooner Row – Impact Assessment(s) Required and Improvements Requests
Developer(s) to provide a transport assessment to show blocking back across level crossings and other effects, including at Spooner Row. NR is happy to discuss with developer before commissioning to ensure right things are covered.
It should not be assumed that development sites will not have any impact and thus should not be allocated favourable in policy for any residential or mix-use allocation with this assumption. Unless it is supported by and of benefit to the railway undertaker or is confirmed to be of no notable detrimental impact to the railway.
NR believe the policy is unsound as it is not ‘positively prepared’ because there is no consideration of safety and other concerns. The plan is not ‘justified’ as there is no appropriate strategy or proportionate evidence to determine why these railway factors are discounted in policy.
Challenge of ‘soundness’ is even more pertinent as there are considerations in ‘Policies VC-SPO 1 - 4’ on highways and Anglia Water, yet there is no reflection of very similar railway requirements. This proposal does not demonstrate that the “area’s objectively assessed needs” have been met regarding sustainable public transport.
Network Rail request the policy be changed and updated to include our railway concerns.
Nearby Level Crossing(s), including Spooner Row – Impact Assessment(s) Required and Improvements Requests
Developer(s) to provide a transport assessment to show blocking back across level crossings and other effects, including at Spooner Row.
Network Rail Consultation Response to the South Norfolk Village Clusters Housing Allocations Plan - Regulation 19 Pre-submission Addendum
Background
Network Rail (NR) is the statutory owner and operator of the national rail infrastructure in England, Scotland and Wales. NR’s focus is on safely and efficiently operating, maintaining, and growing the railway. At this stage, NR has provided both important general and site-specific comments on the South Norfolk Village Clusters Housing Allocations Plan – Regulation 19 Pre-submission Addendum. Of course, Network Rail looks forward to engaging with the South Norfolk Council on this developing policy, and future policies. We also welcome the chance to collaborate further on this, and other, plan(s) and development(s) as they all progress.
Development and Freight
For future development schemes in the South Norfolk area, NR requires that if any new infrastructure requirements affect NR and the operational railway (including Stations, Maintenance Depots, Freight land, etc.) then the appropriate agreements must be entered into by the promotors.
Railway Infrastructure (and Level Crossings)
NR has a key requirement to manage risk appropriately for all rail infrastructure on safety grounds, to reduce risk so that it is as low as reasonably practicable. This is especially important when developments occur near existing infrastructure as these new communities can create a substantial increase in the risk if not mitigated. This increase in risk can impact safety, efficiency, and operational performance. NR is not bound to accommodate changes in the use of private land that impose a greater burden on the railway and will object to all proposals where an adverse impact on the railway is reasonably foreseeable. NR also requests that any developer and other key stakeholders engage with us early to discuss opportunities and enter into the necessary agreements. Where rail infrastructure will be affected by a development, for example, new crossings of the railway are possible, but these must be by bridge, and we would expect the resulting structure to be vested in the highway authority or another statutory undertaker. In all cases where new crossings of the railway are required, NR’s shared value policy will apply.
There may also be some road bridges where enhancements to footway provision (necessitating a widening or restriction on traffic) are suitable. Again, we would expect the developer(s) to fund any such works. Aside from bridges and crossings, improvement to railway boundary fences may be required if areas that are currently remote are developed for housing or industry. We would expect developers to fund necessary upgrades.
Nearby Level Crossing(s), including Spooner Row – Impact Assessment(s) Required and Improvements Requests
Developer(s) to provide a transport assessment to show blocking back across level crossings and other effects, including at Spooner Row. NR is happy to discuss with developer before commissioning to ensure right things are covered.
If measures short of a bridge at the station are justified by the number of houses, we should consider other station improvements such as (purely for example) additional ticket machines, access improvements, signage, waiting facilities, lighting, etc. all to be subject to further discussion once developer has modelled likely use of the respective stations such as Spooner Row.
Future Policy and Developer Engagement
NR would welcome the opportunity to discuss further policy and possible site policy protection and infrastructure intensification of land in, and neighbouring, South Norfolk. Whether the extent of this/other SPDs, Policies, and plan(s) impacts NR on the local, regional, or national level. We particularly welcome the opportunity to work with the Council in relation to its urban expansion/regeneration aspirations. NR places importance on infrastructure plans and intensification of sites impacting the operational railway.
Therefore, it should not be assumed that development sites will not have any impact and thus should not be allocated favourable in policy for any residential or mix-use allocation with this assumption. Unless it is supported by and of benefit to the railway undertaker or is confirmed to be of no notable detrimental impact to the railway.
NR believe the policy is unsound as it is not ‘positively prepared’ (Paragraph 35a - NPPF, 2023) because there is no consideration of safety concerns, amongst other highlighted rail concerns, onto and along the railway from an increase to proposed housing allocation numbers. Furthermore, the plan is not ‘justified’ (Paragraph 35b - NPPF, 2023) as there is no appropriate strategy or proportionate evidence to determine these railway factors can and should be discounted in policy – Factors which NR believes should not be discounted.
This challenge of ‘soundness’ is even more pertinent once you acknowledge there are considerations in ‘Policies VC-SPO 1 - 4’ on safety concerns over the highway, as well as a requirement for early engagement with another utility statutory undertaker (i.e., Anglia Water), yet there is no reflection of very similar railway requirements for these sites located at Spooner Row. Furthermore, this proposal does not demonstrate that the “area’s objectively assessed needs” have been met regarding sustainable public transport. Especially when you remember that there is no position reached that was informed by Network Rail (i.e., a “other [suitable] authorities[y]” – Para 35a, NPPF, 2023) regarding the railway line, level crossing and railway station running in between these site allocations.
Therefore, Network Rail request the policy be changed and updated to include our railway concerns, especially over safety, proposed impact assessments undertaken from new housing developments, and required agreements before these allocations can be deemed to promote and achieve ‘sustainable development’ (Paragraph 8 - NPPF, 2023).
Object
Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum
Policy VC SPO2: South of Station Road
Representation ID: 4023
Received: 03/10/2024
Respondent: Network Rail Ltd
Legally compliant? No
Sound? No
Duty to co-operate? No
NR has provided both important general and site-specific comments on the South Norfolk Village Clusters Housing Allocations Plan – Regulation 19 Pre-submission Addendum.
For future development schemes in the South Norfolk area, NR requires that if any new infrastructure requirements affect NR and the operational railway then the appropriate agreements must be entered into by the promotors.
NR has a key requirement to manage risk appropriately for all rail infrastructure on safety grounds, to reduce risk so that it is as low as reasonably practicable. NR also requests that any developer and other key stakeholders engage with us early to discuss opportunities and enter into the necessary agreements.
Nearby Level Crossing(s), including Spooner Row – Impact Assessment(s) Required and Improvements Requests
Developer(s) to provide a transport assessment to show blocking back across level crossings and other effects, including at Spooner Row. NR is happy to discuss with developer before commissioning to ensure right things are covered.
It should not be assumed that development sites will not have any impact and thus should not be allocated favourable in policy for any residential or mix-use allocation with this assumption. Unless it is supported by and of benefit to the railway undertaker or is confirmed to be of no notable detrimental impact to the railway.
NR believe the policy is unsound as it is not ‘positively prepared’ because there is no consideration of safety and other concerns. The plan is not ‘justified’ as there is no appropriate strategy or proportionate evidence to determine why these railway factors are discounted in policy.
Challenge of ‘soundness’ is even more pertinent as there are considerations in ‘Policies VC-SPO 1 - 4’ on highways and Anglia Water, yet there is no reflection of very similar railway requirements. This proposal does not demonstrate that the “area’s objectively assessed needs” have been met regarding sustainable public transport.
Network Rail request the policy be changed and updated to include our railway concerns.
Nearby Level Crossing(s), including Spooner Row – Impact Assessment(s) Required and Improvements Requests
Developer(s) to provide a transport assessment to show blocking back across level crossings and other effects, including at Spooner Row.
Network Rail Consultation Response to the South Norfolk Village Clusters Housing Allocations Plan - Regulation 19 Pre-submission Addendum
Background
Network Rail (NR) is the statutory owner and operator of the national rail infrastructure in England, Scotland and Wales. NR’s focus is on safely and efficiently operating, maintaining, and growing the railway. At this stage, NR has provided both important general and site-specific comments on the South Norfolk Village Clusters Housing Allocations Plan – Regulation 19 Pre-submission Addendum. Of course, Network Rail looks forward to engaging with the South Norfolk Council on this developing policy, and future policies. We also welcome the chance to collaborate further on this, and other, plan(s) and development(s) as they all progress.
Development and Freight
For future development schemes in the South Norfolk area, NR requires that if any new infrastructure requirements affect NR and the operational railway (including Stations, Maintenance Depots, Freight land, etc.) then the appropriate agreements must be entered into by the promotors.
Railway Infrastructure (and Level Crossings)
NR has a key requirement to manage risk appropriately for all rail infrastructure on safety grounds, to reduce risk so that it is as low as reasonably practicable. This is especially important when developments occur near existing infrastructure as these new communities can create a substantial increase in the risk if not mitigated. This increase in risk can impact safety, efficiency, and operational performance. NR is not bound to accommodate changes in the use of private land that impose a greater burden on the railway and will object to all proposals where an adverse impact on the railway is reasonably foreseeable. NR also requests that any developer and other key stakeholders engage with us early to discuss opportunities and enter into the necessary agreements. Where rail infrastructure will be affected by a development, for example, new crossings of the railway are possible, but these must be by bridge, and we would expect the resulting structure to be vested in the highway authority or another statutory undertaker. In all cases where new crossings of the railway are required, NR’s shared value policy will apply.
There may also be some road bridges where enhancements to footway provision (necessitating a widening or restriction on traffic) are suitable. Again, we would expect the developer(s) to fund any such works. Aside from bridges and crossings, improvement to railway boundary fences may be required if areas that are currently remote are developed for housing or industry. We would expect developers to fund necessary upgrades.
Nearby Level Crossing(s), including Spooner Row – Impact Assessment(s) Required and Improvements Requests
Developer(s) to provide a transport assessment to show blocking back across level crossings and other effects, including at Spooner Row. NR is happy to discuss with developer before commissioning to ensure right things are covered.
If measures short of a bridge at the station are justified by the number of houses, we should consider other station improvements such as (purely for example) additional ticket machines, access improvements, signage, waiting facilities, lighting, etc. all to be subject to further discussion once developer has modelled likely use of the respective stations such as Spooner Row.
Future Policy and Developer Engagement
NR would welcome the opportunity to discuss further policy and possible site policy protection and infrastructure intensification of land in, and neighbouring, South Norfolk. Whether the extent of this/other SPDs, Policies, and plan(s) impacts NR on the local, regional, or national level. We particularly welcome the opportunity to work with the Council in relation to its urban expansion/regeneration aspirations. NR places importance on infrastructure plans and intensification of sites impacting the operational railway.
Therefore, it should not be assumed that development sites will not have any impact and thus should not be allocated favourable in policy for any residential or mix-use allocation with this assumption. Unless it is supported by and of benefit to the railway undertaker or is confirmed to be of no notable detrimental impact to the railway.
NR believe the policy is unsound as it is not ‘positively prepared’ (Paragraph 35a - NPPF, 2023) because there is no consideration of safety concerns, amongst other highlighted rail concerns, onto and along the railway from an increase to proposed housing allocation numbers. Furthermore, the plan is not ‘justified’ (Paragraph 35b - NPPF, 2023) as there is no appropriate strategy or proportionate evidence to determine these railway factors can and should be discounted in policy – Factors which NR believes should not be discounted.
This challenge of ‘soundness’ is even more pertinent once you acknowledge there are considerations in ‘Policies VC-SPO 1 - 4’ on safety concerns over the highway, as well as a requirement for early engagement with another utility statutory undertaker (i.e., Anglia Water), yet there is no reflection of very similar railway requirements for these sites located at Spooner Row. Furthermore, this proposal does not demonstrate that the “area’s objectively assessed needs” have been met regarding sustainable public transport. Especially when you remember that there is no position reached that was informed by Network Rail (i.e., a “other [suitable] authorities[y]” – Para 35a, NPPF, 2023) regarding the railway line, level crossing and railway station running in between these site allocations.
Therefore, Network Rail request the policy be changed and updated to include our railway concerns, especially over safety, proposed impact assessments undertaken from new housing developments, and required agreements before these allocations can be deemed to promote and achieve ‘sustainable development’ (Paragraph 8 - NPPF, 2023).
Object
Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum
Policy VC SPO3: Land at School Lane
Representation ID: 4024
Received: 03/10/2024
Respondent: Network Rail Ltd
Legally compliant? No
Sound? No
Duty to co-operate? No
NR has provided both important general and site-specific comments on the South Norfolk Village Clusters Housing Allocations Plan – Regulation 19 Pre-submission Addendum.
For future development schemes in the South Norfolk area, NR requires that if any new infrastructure requirements affect NR and the operational railway then the appropriate agreements must be entered into by the promotors.
NR has a key requirement to manage risk appropriately for all rail infrastructure on safety grounds, to reduce risk so that it is as low as reasonably practicable. NR also requests that any developer and other key stakeholders engage with us early to discuss opportunities and enter into the necessary agreements.
Nearby Level Crossing(s), including Spooner Row – Impact Assessment(s) Required and Improvements Requests
Developer(s) to provide a transport assessment to show blocking back across level crossings and other effects, including at Spooner Row. NR is happy to discuss with developer before commissioning to ensure right things are covered.
It should not be assumed that development sites will not have any impact and thus should not be allocated favourable in policy for any residential or mix-use allocation with this assumption. Unless it is supported by and of benefit to the railway undertaker or is confirmed to be of no notable detrimental impact to the railway.
NR believe the policy is unsound as it is not ‘positively prepared’ because there is no consideration of safety and other concerns. The plan is not ‘justified’ as there is no appropriate strategy or proportionate evidence to determine why these railway factors are discounted in policy.
Challenge of ‘soundness’ is even more pertinent as there are considerations in ‘Policies VC-SPO 1 - 4’ on highways and Anglia Water, yet there is no reflection of very similar railway requirements. This proposal does not demonstrate that the “area’s objectively assessed needs” have been met regarding sustainable public transport.
Network Rail request the policy be changed and updated to include our railway concerns.
Nearby Level Crossing(s), including Spooner Row – Impact Assessment(s) Required and Improvements Requests
Developer(s) to provide a transport assessment to show blocking back across level crossings and other effects, including at Spooner Row.
Network Rail Consultation Response to the South Norfolk Village Clusters Housing Allocations Plan - Regulation 19 Pre-submission Addendum
Background
Network Rail (NR) is the statutory owner and operator of the national rail infrastructure in England, Scotland and Wales. NR’s focus is on safely and efficiently operating, maintaining, and growing the railway. At this stage, NR has provided both important general and site-specific comments on the South Norfolk Village Clusters Housing Allocations Plan – Regulation 19 Pre-submission Addendum. Of course, Network Rail looks forward to engaging with the South Norfolk Council on this developing policy, and future policies. We also welcome the chance to collaborate further on this, and other, plan(s) and development(s) as they all progress.
Development and Freight
For future development schemes in the South Norfolk area, NR requires that if any new infrastructure requirements affect NR and the operational railway (including Stations, Maintenance Depots, Freight land, etc.) then the appropriate agreements must be entered into by the promotors.
Railway Infrastructure (and Level Crossings)
NR has a key requirement to manage risk appropriately for all rail infrastructure on safety grounds, to reduce risk so that it is as low as reasonably practicable. This is especially important when developments occur near existing infrastructure as these new communities can create a substantial increase in the risk if not mitigated. This increase in risk can impact safety, efficiency, and operational performance. NR is not bound to accommodate changes in the use of private land that impose a greater burden on the railway and will object to all proposals where an adverse impact on the railway is reasonably foreseeable. NR also requests that any developer and other key stakeholders engage with us early to discuss opportunities and enter into the necessary agreements. Where rail infrastructure will be affected by a development, for example, new crossings of the railway are possible, but these must be by bridge, and we would expect the resulting structure to be vested in the highway authority or another statutory undertaker. In all cases where new crossings of the railway are required, NR’s shared value policy will apply.
There may also be some road bridges where enhancements to footway provision (necessitating a widening or restriction on traffic) are suitable. Again, we would expect the developer(s) to fund any such works. Aside from bridges and crossings, improvement to railway boundary fences may be required if areas that are currently remote are developed for housing or industry. We would expect developers to fund necessary upgrades.
Nearby Level Crossing(s), including Spooner Row – Impact Assessment(s) Required and Improvements Requests
Developer(s) to provide a transport assessment to show blocking back across level crossings and other effects, including at Spooner Row. NR is happy to discuss with developer before commissioning to ensure right things are covered.
If measures short of a bridge at the station are justified by the number of houses, we should consider other station improvements such as (purely for example) additional ticket machines, access improvements, signage, waiting facilities, lighting, etc. all to be subject to further discussion once developer has modelled likely use of the respective stations such as Spooner Row.
Future Policy and Developer Engagement
NR would welcome the opportunity to discuss further policy and possible site policy protection and infrastructure intensification of land in, and neighbouring, South Norfolk. Whether the extent of this/other SPDs, Policies, and plan(s) impacts NR on the local, regional, or national level. We particularly welcome the opportunity to work with the Council in relation to its urban expansion/regeneration aspirations. NR places importance on infrastructure plans and intensification of sites impacting the operational railway.
Therefore, it should not be assumed that development sites will not have any impact and thus should not be allocated favourable in policy for any residential or mix-use allocation with this assumption. Unless it is supported by and of benefit to the railway undertaker or is confirmed to be of no notable detrimental impact to the railway.
NR believe the policy is unsound as it is not ‘positively prepared’ (Paragraph 35a - NPPF, 2023) because there is no consideration of safety concerns, amongst other highlighted rail concerns, onto and along the railway from an increase to proposed housing allocation numbers. Furthermore, the plan is not ‘justified’ (Paragraph 35b - NPPF, 2023) as there is no appropriate strategy or proportionate evidence to determine these railway factors can and should be discounted in policy – Factors which NR believes should not be discounted.
This challenge of ‘soundness’ is even more pertinent once you acknowledge there are considerations in ‘Policies VC-SPO 1 - 4’ on safety concerns over the highway, as well as a requirement for early engagement with another utility statutory undertaker (i.e., Anglia Water), yet there is no reflection of very similar railway requirements for these sites located at Spooner Row. Furthermore, this proposal does not demonstrate that the “area’s objectively assessed needs” have been met regarding sustainable public transport. Especially when you remember that there is no position reached that was informed by Network Rail (i.e., a “other [suitable] authorities[y]” – Para 35a, NPPF, 2023) regarding the railway line, level crossing and railway station running in between these site allocations.
Therefore, Network Rail request the policy be changed and updated to include our railway concerns, especially over safety, proposed impact assessments undertaken from new housing developments, and required agreements before these allocations can be deemed to promote and achieve ‘sustainable development’ (Paragraph 8 - NPPF, 2023).
Object
Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum
Table at paragraph 1A.10:
Representation ID: 4035
Received: 03/10/2024
Respondent: Network Rail Ltd
Legally compliant? No
Sound? No
Duty to co-operate? No
Representations relate to VC SPO4:
NR has provided both important general and site-specific comments on the South Norfolk Village Clusters Housing Allocations Plan – Regulation 19 Pre-submission Addendum.
For future development schemes in the South Norfolk area, NR requires that if any new infrastructure requirements affect NR and the operational railway then the appropriate agreements must be entered into by the promotors.
NR has a key requirement to manage risk appropriately for all rail infrastructure on safety grounds, to reduce risk so that it is as low as reasonably practicable. NR also requests that any developer and other key stakeholders engage with us early to discuss opportunities and enter into the necessary agreements.
Nearby Level Crossing(s), including Spooner Row – Impact Assessment(s) Required and Improvements Requests
Developer(s) to provide a transport assessment to show blocking back across level crossings and other effects, including at Spooner Row. NR is happy to discuss with developer before commissioning to ensure right things are covered.
It should not be assumed that development sites will not have any impact and thus should not be allocated favourable in policy for any residential or mix-use allocation with this assumption. Unless it is supported by and of benefit to the railway undertaker or is confirmed to be of no notable detrimental impact to the railway.
NR believe the policy is unsound as it is not ‘positively prepared’ because there is no consideration of safety and other concerns. The plan is not ‘justified’ as there is no appropriate strategy or proportionate evidence to determine why these railway factors are discounted in policy.
Challenge of ‘soundness’ is even more pertinent as there are considerations in ‘Policies VC-SPO 1 - 4’ on highways and Anglia Water, yet there is no reflection of very similar railway requirements. This proposal does not demonstrate that the “area’s objectively assessed needs” have been met regarding sustainable public transport.
Network Rail request the policy be changed and updated to include our railway concerns.
Nearby Level Crossing(s), including Spooner Row – Impact Assessment(s) Required and Improvements Requests
Developer(s) to provide a transport assessment to show blocking back across level crossings and other effects, including at Spooner Row.
Network Rail Consultation Response to the South Norfolk Village Clusters Housing Allocations Plan - Regulation 19 Pre-submission Addendum
Background
Network Rail (NR) is the statutory owner and operator of the national rail infrastructure in England, Scotland and Wales. NR’s focus is on safely and efficiently operating, maintaining, and growing the railway. At this stage, NR has provided both important general and site-specific comments on the South Norfolk Village Clusters Housing Allocations Plan – Regulation 19 Pre-submission Addendum. Of course, Network Rail looks forward to engaging with the South Norfolk Council on this developing policy, and future policies. We also welcome the chance to collaborate further on this, and other, plan(s) and development(s) as they all progress.
Development and Freight
For future development schemes in the South Norfolk area, NR requires that if any new infrastructure requirements affect NR and the operational railway (including Stations, Maintenance Depots, Freight land, etc.) then the appropriate agreements must be entered into by the promotors.
Railway Infrastructure (and Level Crossings)
NR has a key requirement to manage risk appropriately for all rail infrastructure on safety grounds, to reduce risk so that it is as low as reasonably practicable. This is especially important when developments occur near existing infrastructure as these new communities can create a substantial increase in the risk if not mitigated. This increase in risk can impact safety, efficiency, and operational performance. NR is not bound to accommodate changes in the use of private land that impose a greater burden on the railway and will object to all proposals where an adverse impact on the railway is reasonably foreseeable. NR also requests that any developer and other key stakeholders engage with us early to discuss opportunities and enter into the necessary agreements. Where rail infrastructure will be affected by a development, for example, new crossings of the railway are possible, but these must be by bridge, and we would expect the resulting structure to be vested in the highway authority or another statutory undertaker. In all cases where new crossings of the railway are required, NR’s shared value policy will apply.
There may also be some road bridges where enhancements to footway provision (necessitating a widening or restriction on traffic) are suitable. Again, we would expect the developer(s) to fund any such works. Aside from bridges and crossings, improvement to railway boundary fences may be required if areas that are currently remote are developed for housing or industry. We would expect developers to fund necessary upgrades.
Nearby Level Crossing(s), including Spooner Row – Impact Assessment(s) Required and Improvements Requests
Developer(s) to provide a transport assessment to show blocking back across level crossings and other effects, including at Spooner Row. NR is happy to discuss with developer before commissioning to ensure right things are covered.
If measures short of a bridge at the station are justified by the number of houses, we should consider other station improvements such as (purely for example) additional ticket machines, access improvements, signage, waiting facilities, lighting, etc. all to be subject to further discussion once developer has modelled likely use of the respective stations such as Spooner Row.
Future Policy and Developer Engagement
NR would welcome the opportunity to discuss further policy and possible site policy protection and infrastructure intensification of land in, and neighbouring, South Norfolk. Whether the extent of this/other SPDs, Policies, and plan(s) impacts NR on the local, regional, or national level. We particularly welcome the opportunity to work with the Council in relation to its urban expansion/regeneration aspirations. NR places importance on infrastructure plans and intensification of sites impacting the operational railway.
Therefore, it should not be assumed that development sites will not have any impact and thus should not be allocated favourable in policy for any residential or mix-use allocation with this assumption. Unless it is supported by and of benefit to the railway undertaker or is confirmed to be of no notable detrimental impact to the railway.
NR believe the policy is unsound as it is not ‘positively prepared’ (Paragraph 35a - NPPF, 2023) because there is no consideration of safety concerns, amongst other highlighted rail concerns, onto and along the railway from an increase to proposed housing allocation numbers. Furthermore, the plan is not ‘justified’ (Paragraph 35b - NPPF, 2023) as there is no appropriate strategy or proportionate evidence to determine these railway factors can and should be discounted in policy – Factors which NR believes should not be discounted.
This challenge of ‘soundness’ is even more pertinent once you acknowledge there are considerations in ‘Policies VC-SPO 1 - 4’ on safety concerns over the highway, as well as a requirement for early engagement with another utility statutory undertaker (i.e., Anglia Water), yet there is no reflection of very similar railway requirements for these sites located at Spooner Row. Furthermore, this proposal does not demonstrate that the “area’s objectively assessed needs” have been met regarding sustainable public transport. Especially when you remember that there is no position reached that was informed by Network Rail (i.e., a “other [suitable] authorities[y]” – Para 35a, NPPF, 2023) regarding the railway line, level crossing and railway station running in between these site allocations.
Therefore, Network Rail request the policy be changed and updated to include our railway concerns, especially over safety, proposed impact assessments undertaken from new housing developments, and required agreements before these allocations can be deemed to promote and achieve ‘sustainable development’ (Paragraph 8 - NPPF, 2023).