Design
Policy POSP16: Strategic Design Policy
- Development proposals in the Broads must:
- Protect and enhance the distinctive built and landscape character of the settlements in the Broads;
- Ensure new developments are of a quality that will be enduring and can become the heritage of the future;
- Be resilient to a changing climate and minimise carbon emissions and waste, including through reducing car use.
Reasoned justification
Good design creates real benefits for communities - increasing pride in place, making healthier, safer environments, creating economic benefit and lowering carbon emissions.
Conversely, poor design results in tangible harm. Poor design creates environments that are not attractive to live in, work in, or to visit. This causes harm to local pride in place and erodes the distinctive identity of our built heritage and landscapes. It also erodes prospects for economic growth as liveable, attractive environments are an important factor in attracting and retaining businesses and residents. Buildings and spaces that are poorly designed not only use more energy, and are responsible for more carbon emissions, than well-designed spaces; they can have a shorter lifespan and require demolition or substantial redevelopment within decades, rather than the centuries that our best-loved places have survived. This wastes the embodied carbon ‘locked into’ their building fabric. Poor design can also lead to increased maintenance and long-term management costs, as well as the indirect costs from ill-health caused by inactive lifestyles, poorly designed and constructed building fabric, or overheating; from the need to police poorly laid out spaces without natural surveillance; and from many other causes.
One of the purposes of the purposes of the Broads Authority is conserving and enhancing the natural beauty, wildlife, and cultural heritage of the Broads and this is reflected in this Local Plan.
Well-designed, distinctive places with a strong and positive character make better environments for all parts of our community. Creating and enhancing the quality of our environment is central to our Local Plan.
Reasonable alternative options
No policy
Sustainability appraisal summary
The following is a summary of the assessment of the policy and alternative(s).
A: Have a policy: 5 positives. 0 negatives. 0 ? Overall, positive.
B: No policy: 0 positives. 0 negatives. 5 ?
Why has the alternative option been discounted?
Generally, a strategic policy relating to design that captures the fundamental issues that schemes need to address is favoured.
Policy PODM51: Design
- All development will be expected to be of a high design quality.
- Development should integrate effectively with its surroundings, reinforce local distinctiveness, and landscape character and preserve or enhance cultural heritage. Innovative designs will be encouraged where appropriate.
- Applicants will need to fill out the Design Checklist at Appendix 12 to accompany any application.
- Proposals will be assessed to ensure they effectively address the following matters:
- Siting and layout: The siting and layout of a development must reflect the characteristics of the site in terms of its appearance and function and be an easy to navigate environment. Existing mature trees and landscape features are to be used as the focal point of the layout. Sensitive design should provide sufficient daylight and sunlight to new housing while not obstructing light to existing homes nearby[145].
- Relationship to surroundings and to other development: Development proposals must complement the character of the local area and reinforce the distinctiveness of the wider Broads setting. In particular, development shall respond to surrounding buildings and the distinctive features or qualities that contribute to the landscape, streetscape and waterscape quality of the local area.
- Permeability: Design shall also promote permeability and accessibility by ensuring ease of movement between homes, jobs, and services and by creating links to public transport services.
- Mix of uses: To create vitality and interest, proposals should incorporate a mix of uses where possible and appropriate.
- Density, scale, form, and massing: The density, scale, form, massing and height of a development must be appropriate to the local context of the site and to the surrounding landscape/streetscape /waterscape character.
- Appropriate facilities: Development shall incorporate appropriate waste management and storage facilities, provision for the storage of bicycles, and connection to communication networks.
- Detailed design and materials: The detailing and materials of a building and its boundary treatment must be of high quality and appropriate to its context. New development should employ sustainable materials, building techniques and technology where appropriate. Proposals shall minimise construction waste. In particular, where appropriate, joinery including windows and doors, shall use appropriate materials and be detailed to reflect local traditions and character. Where a thatched building is proposed to be replaced, the new building must also have a thatched roof, except in exceptional circumstances where sufficient justification can be provided, and an acceptable alternative has been proposed.
- Crime prevention: The design and layout of development should be safe and secure, with natural surveillance. Measures to reduce the risk of crime and antisocial behaviour should be considered at an early stage so as not to be at the expense of overall design quality. Schemes should address Secured by Design standards and be in line with Crime Prevention Through Environmental Design (CTPED) Principles as appropriate.
- Accessibility and adaptability: Developments shall be capable of adapting to changing circumstances, in terms of occupiers, use and climate change (including changes in water level). In particular, dwelling houses should be able to adapt to changing family circumstances or ageing of the occupier(s) and commercial premises should be able to respond to changes in industry or the economic base. Applicants are required to consider if it is appropriate for their proposed dwelling/ some of the dwellings to be built so they are accessible and adaptable and meet Building Regulation standard M4(2) and M4(3). If applicants do not consider it appropriate, they need to justify this. For developments of five dwellings or more, 20% will be built to meet Building Regulation Standard M4(2). If proposal would not meet policy standards, there will be a need to provide evidence to demonstrate that meeting the policy is not financially viable or that there is no unmet need for accessible and adaptable housing.
- On site utilities infrastructure: proposals need to fully understand and address any on site utilities infrastructure which may be on, under, over or close by to the site.
- Sustainable development: proposals are required to fundamentally be sustainable. Example areas include adapting to different uses without the need for demolition, considering the embodied carbon of a property, being designed to make the most of solar gain, address overheating and be water efficient. See Sustainable Development section of this Local Plan.
- Flood risk and resilience: Development shall be designed to reduce flood risk but still be of a scale and design appropriate to its Broads setting. Traditional or innovative approaches may be employed to reduce the risks and effects of flooding. See flood risk section of this Local Plan.
- Biodiversity: The design and layout of development shall aim to protect, provide for, restore, and enhance biodiversity. See the Natural Environment section of this Local Plan.
- High quality landscaping. All proposals shall be designed to respond to and integrate effectively with the landscape character of the area, making a positive contribution through a high-quality landscaping scheme as appropriate. See the Landscape section of this Local Plan.
Reasoned Justification
Good design is vital for protecting and enhancing the special character of the Broads and for achieving truly sustainable development. The design principles set out in this policy provide a high-level framework for new development that supports the diverse nature of good design. All development proposals should demonstrate compliance with the design principles in the policy. Where development proposals need to be accompanied by a Design and Access Statement, it should be used to explain how the principles of good design, including the criteria set out in this policy, have been incorporated into the development. The following text explains the criteria in the policy.
As stated in paragraph 131 of the NPPF (2023) “The creation of high quality, beautiful and sustainable buildings and places is fundamental to what the planning and development process should achieve.”
As set out in the National Design Guide (2021), a well-designed place comes through making the right choices at all levels including layout, form and scale of buildings, appearance, landscape, and materials. Several other characteristics include the climate, character, and community. The ten characteristics set out in the National Design Guide reflect the importance of a well-designed place. Well-designed places have individual characteristics which work together to create its physical Character. The ten characteristics help to nurture and sustain a sense of Community. They work to positively address environmental issues affecting Climate. They all contribute towards the cross-cutting themes for good design set out in the National Planning Policy Framework.
Design Guides
The Authority is finalising a Design Guide and that will set out key requirements for schemes in the Broads to consider. Furthermore, some Neighbourhood Plans that have been made also have design guides and again set out key requirements to address when designing schemes.
Siting and layout
Easy to navigate environments can help everyone, especially those with mobility issues, sight loss or dementia, to live well, by being designed to be familiar, legible, distinctive, accessible, comfortable, and safe. Having access to amenities like local shops, doctors, post offices and banks within easy, safe, and comfortable walking distances help people with dementia to live independent and fulfilling lives for longer. There are many guides that can help design better environments, such as:
- BS 8300: 2009+A1:2010 looks at the design of buildings and their ability to meet the requirements of disabled people.
- The RTPI have produced DEMENTIA AND TOWN PLANNING (2020) RTPI | Dementia and Town Planning
- Neighbourhoods for Life - Designing dementia-friendly outdoor environments: www.idgo.ac.uk/about_idgo/docs/NfL-FL.pdf
Relationship to surroundings and to other development
Development proposals should not be designed in isolation from their context. Although there is considerable variation in local architectural styles, buildings in the Broads are typically of simple construction, often from lightweight materials, and of a scale which blends with their natural surroundings. New development should take account of the characteristics of the site, as well as the distinctiveness of the wider Broads’ setting, and make a positive contribution to the surrounding area. The density, scale and mix should be compatible with the character of the local area and avoid adverse impacts of development on views, vistas, and skylines. In accordance with the NPPF and NPPG, the Authority considers design to be of great importance and development will not be acceptable if its design is inappropriate in its context or fails to take opportunities available for improving the character and quality of an area and the way it functions. In the interests of sustainability and good design, it is also important to promote ease of movement within and between places where people live, and between these places and workplaces and other amenities and services.
Appropriate facilities
Appropriate facilities for users of new development should be integrated effectively into its design and layout so they can be accessed in a safe and convenient manner and do not detract from the overall appearance of the development. The nature of the facilities will vary depending on the development proposed but should include waste management and storage facilities to aid recycling, provision for the safe, secure, and user-friendly storage of bicycles in locations convenient to the cyclist, with good natural or CCTV surveillance to help reduce cycle theft, and connection to telephone and broadband networks.
Density, scale, form, and massing
Particular attention should be given to details regarding the appearance of development in the Broads’ landscape. This should consider the form, mass and scale of a building or structure. Proposals should also consider the texture, colour, pattern, and durability of materials used and reference Broads’ vernacular and local detailing. Materials should aim to conserve and enhance the local identity and distinctiveness of the built environment and landscape character. Non-traditional unsustainable materials will be resisted if they are not considered to be a high-quality material appropriate to context or able to contribute to local distinctiveness. Many modern materials have a uniform and applied texture which does not weather or soften over time. Individually and cumulatively these materials are considered to erode the distinctive character of the Broads and will become increasingly incongruous in the area. However, it is acknowledged that there will be instances when modern construction methods and design solutions may necessitate the use of other sustainable materials.
Crime prevention
The safety and security of the users of new development is an important consideration at an early stage in the design process. The attributes of good design include safer places. Well-designed development will create safe, sustainable, and attractive places to live and work. It is important that new development is designed to minimise both the opportunity for crime and the perception or fear of crime, while ensuring that other planning and design objectives are not compromised. Secured by Design aims to achieve a good standard of security for buildings and the immediate environment. There are Residential, Commercial, Hospital and Educational Developments Design Guides available from www.securedbydesign.com which explain all the crime reduction elements of these schemes. The interactive design guide https://www.securedbydesign.com/guidance/interactive-design-guide is also a very good and self-explanatory tool that can walk you through the various elements of designing out crime in a visual manner.
Building for a Healthy Life
Assessing design quality for major applications for residential development will be made using the Building for a Healthy Life[146] criteria, which are reflected in this policy. Applicants will be expected to demonstrate that the scheme positively addresses relevant categories within the Building for a Healthy Life criteria.
Detailed design and materials
Thatch is an important vernacular material in the Broads, the use of which is declining. The policy ensures that the use of thatch continues to contribute to the character of the Broads area and retains and strengthens the cultural heritage of the area, including heritage skills such as reed and sedge cutting and thatching.
Window replacements are often the most serious threat to the appearance of buildings and wider character of areas and may even affect the value of properties. The replacement of timber windows with PVCu is likely to result in several problems:
- The material cannot reproduce profiles and detailing of traditional joinery due to the limitation in the manufacturing process meaning sections are often heavy and bulky (which can also affect light levels).
- The variety in design can destroy the visual harmony of a street/ river scene.
- The material remains visually prominent for its lifetime, does not weather well and can be too harsh against softer traditional materials of traditional buildings.
- The material is not as easy and economical to repair as timber.
- It does not have the biodegradable qualities of timber when redundant, creating an environmental land fill hazard.
There are other alternative, low maintenance, and high quality materials available, such as aluminium, which does not have the same sustainability issues as uPVC and can in some instances be considered appropriate on design grounds, depending on the building age/design.
It is important that proposals can accommodate access by emergency service vehicles and waste disposal vehicles. Considering the Fire Service in particular, sprinklers are encouraged in developments, and the requirements to include fire hydrants and hard standings for firefighting are judged on a case-by-case basis and may be a planning condition.
Residential refuse storage areas need to meet the requirements of the local waste collection service and demonstrate that commercial development proposals include adequate space for refuse storage and collection. Refuse storage areas need to be enclosed, secure and visually attractive, and user-friendly, integrated with the site and building design. The location and design need to suit the character of the area and development pattern.
Accessibility and adaptability
The Authority also encourages the provision of some dwellings, in appropriate locations, to be designed to be accessible and accommodate wheelchairs. In schemes of 5 dwellings or more it requires 20% to meet Building Regulations part M4(2). The details are set out in the Building Regulations part M[147] . In summary:
- The Census 2021 shows that the Broads Authority Executive Area has an ageing population, with 30% 36.6% of the population being over 65 and 22% are disabled under the Equality Act and 23% of people saying their daily activities are limited.
- The age profile of the Broads is likely to change in a similar manner to our districts. That is to say that the relative proportions of those aged 65 and over and 85 and over will increase by 2035/36. Older people may experience health and mobility issues and it is these issues which the Building Regulations M4(2) seeks to help address.
- Turning to viability, the 2018 Viability Assessment concludes that for new build, the requirement can be designed in from the start at little or no cost. If sites are on steep hills, the cost could increase; but it is recognised that there are very few steep hills in the Broads. For conversions, there could be a slight cost increase but that depends on the level of works to the structure being converted. Generally, the 2018 Viability Assessment concludes that additional base costs of complying with M4(2) are capable of being absorbed and that schemes of 5+ dwellings will be viable. Please note that a viability assessment will be carried out on the next version of the Local Plan and this section will be updated accordingly.
The NPPG[148] is clear, however, in saying that ‘Local Plan policies should also take into account site specific factors such as vulnerability to flooding, site topography, and other circumstances which may make a specific site less suitable for M4(2) and M4(3) compliant dwellings, particularly where step free access cannot be achieved or is not viable. Where step-free access is not viable, neither of the Optional Requirements in Part M should be applied’. The Authority acknowledges that this standard may not be appropriate in some locations or for some schemes, but applicants are required to justify reasons for not including dwellings that are accessible and adaptable.
The Authority is aware of the consultation in 2020 relating to accessibility standards for new homes: Raising accessibility standards for new homes: summary of consultation responses and government response - GOV.UK (www.gov.uk). The Government responded to the consultation saying the following. At the time of writing, the technical consultation had not been released.
- Government proposes that the most appropriate way forward is to mandate the current M4(2) (Category 2: Accessible and adaptable dwellings) requirement in Building Regulations as a minimum standard for all new homes – option 2 in the consultation. M4(1) will apply by exception only, where M4(2) is impractical and unachievable (as detailed below). Subject to a further consultation on the draft technical details, we will implement this change in due course with a change to building regulations.
- M4(3) (Category 3: Wheelchair user dwellings) would continue as now where there is a local planning policy in place in which a need has been identified and evidenced. Local authorities will need to continue to tailor the supply of wheelchair user dwellings to local demand.
High quality landscaping
Landscaping is part of the design response to mitigate and/or enhance a proposal. Some types and forms of hard surfaces and structures or soft landscaping (planting) can have biodiversity, amenity and recreation benefits and are more appropriate in the Broads Executive Area than others. What is suitable on a site would reflect the location and setting. The landscaping design proposals should reflect the key positive characteristics of the locality and its setting. As a minimum, all proposals that are deemed to have a landscape impact will be accompanied by a Landscaping Strategy. The detailed landscaping scheme and management plan will be conditioned should permission be granted. It may be prudent for some schemes to provide the landscaping scheme and management plan as part of the application, rather than using the two-stage approach. The size of the scheme may determine this. See landscaping guide.
Other policies in the Local Plan
When designing new development, consideration should also be given to the design implications set out in other policies in this plan. Of particular relevance are the policies in the Sustainable Development section and policies on landscape, water quality and resources, historic environment, energy generation and efficiency, accessibility on land , accessibility to water, amenity, flood risk, , and . Applicants should also have regard to the planning guides produced by the Authority.[149]
Guidance
- Streets for a Healthy Life - this document has been prepared to illustrate and explain what good residential streets look like, and how they function.
- Building for a Healthy Life: Building for a Healthy Life (BHL) updates England’s most widely known and most widely used design tool for creating places that are better for people and nature.
- Suffolk Design - Suffolk Design is an initiative to ensure the quality of new buildings, public spaces and neighbourhoods throughout the county meets today’s needs and tomorrow’s challenges.
- Home Quality Mark - BRE Group - HQM provides a comprehensive framework for creating homes that are not only environmental and applicants may wish to consider the provisions of HQM.
Reasonable alternative options
The original policy, with no amendments.
No policy
Sustainability appraisal summary
The following is a summary of the assessment of the policy and alternative(s).
A: Keep original policy: 6 positives. 0 negatives. 0 ? Overall, positive.
B: Preferred Option - amend policy: 7 positives. 0 negatives. 0 ? Overall, positive.
C: No policy: 0 positives. 0 negatives. 7 ?
How has the existing policy been used since adoption in May 2019?
According to recent Annual Monitoring Reports, the policy has been used and schemes are in general conformity with the policies.
Why have the alternative options been discounted?
There are often proposals to convert, re-use or change the use of buildings. A policy that seeks to guide such proposals is therefore prudent given the prominence of buildings in the landscape of the Broads. The changes clarify the policy, highlight the opportunities conversion, re-use and change of use to improve the environmental credentials of the schemes as well as refer to embodied carbon.
Policy PODM52: Source of heating
- The Authority encourages the heating system of new buildings to be as high up the heating method hierarchy in section 4 as is feasible.
- New buildings that include heating are required to be:
- heat pump ready (if they do not intend to include heat pumps as part of the initial build). This could be water, ground or air source heat pumps, to reflect the individual circumstances of the scheme and;
- ensure any boiler is hydrogen ready.
- Oil heating of new builds and replacement dwellings will not be supported.
- Proposals for replacement development, as well as proposals to intensify an already permitted use, are required to improve the existing method of heating of the entire property if feasible, in line with the heating method hierarchy as set out below:
- Heat pump and underfloor heating, powered by on-site solar and batteries;
- Heat pump and underfloor heating, powered by the electricity grid;
- Gas heating, but with the overall heating system ‘heat pump ready’ (larger radiators etc);
- Oil Heating, but with the overall heating system ‘heat pump ready’ (larger radiators etc);
- Gas Heating with no adaptation of the system; and
- Oil Heating with no adaptation of the system.
Reasoned justification
Some properties in the Broads are heated by oil. The Department for Business, Energy, and Industrial Strategy (BEIS) estimates domestic gas heating produces much less carbon dioxide emissions than oil heating. The Committee on Climate Change Sixth Carbon Budget Report[150] recommended that for a Balanced Pathway to Net-Zero, new boilers not on the gas grid – e.g. oil-fired boilers - should be low-carbon by 2028. For properties on the gas grid, the target date is 2033. In part this is due to gas boilers having a lower CO2 footprint per kilowatt hour of heat produced.
The policy sets out a preferred method of heating hierarchy in respect of source of heating. Replacement buildings are required to improve their method of heating in line with the hierarchy. New buildings are required to be ready for other heating technologies. In all cases, oil as a source of heating is not supported. The approach of being ready for new or other heating technologies will reduce costs and resource consumption in the long term and make it more affordable to then switch to a low carbon heating system such as a heat pump when gas and oil boilers cease to be available.
It should be noted that towards the end of 2021 there were some Government consultations on fossil fuel heating. It could be that, during the production of the Local Plan, national standards are set.
Reasonable alternative options
No policy
Sustainability appraisal summary
The following is a summary of the assessment of the policy and alternative(s).
A: Have a policy: 4 positives. 0 negatives. 0 ? Overall, positive.
B: No policy: 0 positives. 0 negatives. 4 ?
How has the existing policy been used since adoption in May 2019?
This is a new policy.
Why have the alternative options been discounted?
There was general support for a policy as part of the Issues and Options consultation responses. Given the Climate Emergency and how heating is an important consideration when building homes, a policy is preferred.
Policy PODM53: Heat resilient design
- All schemes for new buildings need to prevent and minimise the impacts of overheating in the built environment.
- Proposals for new buildings must demonstrate, commensurate with the scale and location of the proposal, consideration of:
- How the design of the development minimises overheating and reduces demand on air conditioning systems, including considering:
- How the design of the development minimises overheating and reduces demand on air conditioning systems, including considering:
- orienting buildings to maximise the opportunities for both natural heating and ventilation and to reduce wind exposure;
- measures such as solar shading, thermal mass and appropriately coloured materials in areas exposed to direct and excessive sunlight;
- maximise passive cooling through natural ventilation and other passive means. Reliance on air conditioning systems should be avoided; and
- Provision of shade in public spaces, as appropriate.
- In considering the above, the balance between solar gain versus solar shading will need to be carefully managed.
- The potential to incorporate a green roof and/or walls to aid cooling, add insulation, assist water management and enhance biodiversity, wherever possible linking into a wider network of green infrastructure; unless such roof space is being utilised for photovoltaic or thermal solar panels; or on a whole life cycle basis, it is demonstrated that a lower specification roof has a significantly lower carbon impact than a green roof; or the nature of the development makes it impracticable to incorporate a green roof.
Reasoned Justification
The following diagram shows the UK annual temperatures from 1884 to 2018[151]. Blue are cooler years and red are hotter years. The warmest years have been since 2006. We have experienced the warm temperatures in recent summers locally in Norfolk and Suffolk.
Modelling carried out by the Tyndall Centre[152] shows a significant increase in the incidence of heat related mortality in the UK as the climate warms. This increase is attributable to both rising regional temperatures, but also to an aging population. As the Broads population tends to be older than the UK average, this means a particular focus is needed on ensuring housing is heat resilient.
The policy seeks proposals for new buildings to consider the impact of higher temperatures considering shade, passive cooling and natural ventilation. The policy also applies to the public realm associated with the scheme, seeking shade in public spaces.
Reasonable alternative options
No specific policy
Sustainability appraisal summary
The following is a summary of the assessment of the policy and alternative(s).
A: Preferred Option. 4 positives. 0 negatives. 0 ?
B: No specific policy. 0 positives. 0 negatives. 4 ?
How has the existing policy been used since adoption in May 2019?
This is a new policy.
Why have the alternative options been discounted?
With a changing climate, we are likely to experience more instances of hot weather. So, it will be important to design buildings and the public realm with shade and cooling in mind. As such, a policy is considered prudent. There may be some building regulations in place, but this policy complements them.
Policy PODM54: Non-residential development and BREEAM
- Proposals for non-residential development above 250sqm floor space are required to achieve a minimum of BREEAM Very Good Standard or equivalent unless it can be demonstrated that it is not viable or feasible to do so.
- Development must achieve 3 credits in BREEAM category Wat 01.
Reasoned justification
BREEAM is the world’s leading sustainability assessment method for master planning projects, infrastructure and buildings. Assets are assessed through third party certification, using standards developed by BRE (The Building Research Establishment). BREEAM assesses much wider issues than just energy use, such as water, waste, health and wellbeing and building materials. Each category is sub-divided into a range of assessment issues, each with its own aim, target and benchmarks. When a target or benchmark is reached, as determined by the BREEAM assessor, the development or asset score points, called credits. The category score is then calculated according to the number of credits achieved and its category weighting. Once the development has been fully assessed, the final performance rating is determined by the sum of the weighted category scores. The policy specifies that three water credits are required – this reflects that the area is in water stress.
Compliance will be required through planning conditions including BREEAM certification for non-residential proposals.
Reasonable alternative options
No specific policy
An alternative could be to require a higher rating, such as excellent. The potential for this will be assessed through the whole plan viability assessment. It is not included as an alternative for this version of the Local Plan; we await the viability assessment.
Sustainability appraisal summary
The following is a summary of the assessment of the policy and alternative(s).
A: Preferred Option. 8 positives. 0 negatives. 0 ?
B: No specific policy. 0 positives. 0 negatives. 8 ?
How has the existing policy been used since adoption in May 2019?
This is a new policy.
Why have the alternative options been discounted?
In the current local plan, we focussed just on the water element of BREEAM. However, the BREEAM scheme is not designed to be used in parts. As such, and considering the wider benefits of a scheme being BREEAM compliant, a policy that sets a standard and threshold for BREEAM as a whole is favoured.
Policy PODM55: Electric Vehicle (EV) Charging Points – fire safety, design, location, and lighting.
- Proposals that include the installation of electric vehicle charging points are welcome, but they need to consider the location, design, and lighting of such charging points. In terms of the charging infrastructure, the location, design, and any lighting associated with the charging points will be key considerations.
Location
- Electric vehicle charging points should be placed where the impact of any vehicle or battery igniting/vapour cloud explosion hazard is minimal and to some extent, deemed acceptable. Considerations may include the risk of the spread of fire, and if the fire would prevent escape.
- In terms of electric scooter or bicycle charging, provision in a suitable location for charging of these batteries should be included in a scheme and should be placed where the impact of any vehicle or battery igniting/vapour cloud explosion hazard is minimal and to some extent, deemed acceptable. Considerations may include the risk of the spread of fire, and if the fire would prevent escape.
- EV charging points will be located where they do not cause a hazard or obstruct access. This includes how cables will be laid between the charging point and vehicle.
Design and lighting
- EV charging infrastructure will be designed and located to not negatively impact the townscape, landscape, and dark skies of the Broads.
- Fundamentally, in line with policy PODM27 on dark skies, dark skies will be protected, and light pollution associated with units not permitted.
- Schemes will be required to provide information about how they are to look at night, showing lighting of the units as well as other related lighting.
Reasoned justification
EV charging points for vehicles on land and water are generally welcomed and supported in the Broads, subject to appropriate location, lighting, and design.
Light pollution
The Broads has good dark skies. Different types of EV charging units have varying levels of light associated with them. The units installed in the Broads must address light pollution, comply with policy PODM27 and protect the dark skies of the Broads. Planning applications must show the lighting associated with any units proposed to be installed.
Trip hazards and obstacles
EV charging units need to be sensibly and considerately located to not cause difficulties for those wishing to pass by where they are to be located. Indeed, the cables that link the charging points to the vehicle that is charged are part of this consideration.
Design
Other than lighting, the choice of style of EV charging point needs to be acceptable in terms of design and bulk and scale for the use and its location, particularly considering the historic environment and landscape and townscape character.
Fire Hazard
The risks of an electric vehicle fire are that:
- It occurs very rapidly without much warning;
- The fires are very hot and intense and cannot be easily extinguished and can reignite; and
- The nature of the thermal runaway process is that a lot of very dangerous smoke is produced.
Electric vehicle fires can occur when a battery is damaged, or if there is overcharging. Overcharging should be prevented by software and some technical blocks. However;
- Software can fail
- If a battery is used with a charger that doesn’t match the battery chemistry, it can cause a failure.
At the time of writing, whilst there are regulations addressing the number of charging points for certain developments[153] (and hence no policy is included in the Local Plan relating to that issue), there are no regulations that raise or address the fire risk of electric vehicles. As such, the Authority includes a related policy to ensure applicants consider the location of charging points. If, during the production of this Local Plan, regulations are put in place that address the locations of charging points, the policy may not be required. When considering the location of electric charging points, applicants should think about where is best should the battery/vehicle ignite. It is recommended that this is ideally away from property, and not inside a residential house.
The other safety issue highlighted in this policy is charging of e-bikes and e-scooters. A half kWh battery for example can produce 3000L of smoke very quickly and is powerful enough to devastate a house. A particular concern is the charging of e-scooters and e-bikes in access areas. Provision for charging of such batteries, again in an area where it is deemed acceptable if they were to ignite, should be considered.
Reasonable alternative options
No policy
Sustainability appraisal summary
The following is a summary of the assessment of the policy and alternative(s).
A: No policy: 0 positives. 0 negatives. 6 ?
B: Preferred Option: 6 positives. 0 negatives. 0 ? Overall, positive.
How has the existing policy been used since adoption in May 2019?
This is a new policy.
Why have the alternative options been discounted?
Given the move towards electric vehicles, given the Building Regulations standard in terms of how many and on what property type, but no regulations relating to fire impact and given the issue of batteries/vehicles igniting, a Local Plan response is deemed reasonable and preferred. Further, with some designs of EV charging points having lighting associated with them, the impact on the dark skies is an important consideration. The design and location elements of the policy are favoured because of the potential for impact on the historic environment, townscape, and landscape as well as the potential for units and cables to be obstacles.
Policy PODM56: Fibre to the Premises
1. Prior to first occupation/use, all new dwellings, and all new commercial proposals of 100sqm or over shall be provided with fibre connections to an approved industry standard within the dwelling/building together with suitable ducting/cabling to the public highway to allow connections to be made.
2. Where it can be demonstrated[154] that FTTP is not cost effective, then alternative technological options, for example Superfast Fibre to the Cabinet or Fixed Wireless Access, should be provided. For such schemes provision in the form of ducting and other necessary infrastructure for the future delivery of FTTP should be provided.
Reasoned Justification
The purpose of this policy is to improve the provision and quality of digital communications including broadband across the Broads and to ensure that all new dwellings and workplaces are connected by fibre or are able to be connected in the future. This policy applies to both new build proposals and those seeking the change of use of existing buildings.
High quality digital infrastructure is crucial to the success of businesses and also plays a vital role in enhancing the provision of local community facilities, services, and employment. Well-connected places attract modern businesses and can create the conditions for new clusters of digital and creative businesses to emerge. Access to high quality digital infrastructure can also facilitate social inclusion, enable home working, diversify the rural economy, enhance educational and social opportunities, as well as improve access to a wide range of services that are increasingly provided online. Consequently, high quality digital infrastructure will make a significant contribution towards the delivery of sustainable development.
New development should ensure that it has considered any need and demand resulting from the development and taken proactive steps in engaging with service and infrastructure providers to ensure that there is high-speed fibre broadband connectivity or mobile internet coverage in the development.
Proposals should be supported by a proportionate Digital Infrastructure Connectivity Plan/Statement demonstrating that digital infrastructure has been planned for as part of development proposals. This should provide evidence that developers have engaged with infrastructure and service providers to ascertain fibre connectivity and mobile internet coverage for the site and provide evidence that an agreement to connect to the development site to the fibre broadband network has been secured, and details on how the physical infrastructure on site is capable of supporting gigabit-capable networks. Where there are deficiencies in mobile coverage, development proposals must provide information on how the coverage is to be improved if practicable.
Reasonable alternative options
No specific policy.
Sustainability appraisal summary
The following is a summary of the assessment of the policy and alternative(s).
A: Preferred Option – policy on fibre to the premises . 3 positives. 0 negatives. 0 ?
B: No specific policy. 0 positives. 0 negatives. 3 ?
How has the existing policy been used since adoption in May 2019?
This is a new policy.
Why have the alternative options been discounted?
Given that access to high quality digital infrastructure can also facilitate social inclusion, enable home working, diversify the rural economy, enhance educational and social opportunities, as well as improve access to a wide range of services that are increasingly provided online, it is felt a policy is prudent.
[147] Building Regulations Part M Access to and use of buildings (pdf | publishing.service.gov.uk) ↑
[150] https://www.theccc.org.uk/publication/sixth-carbon-budget page 110-112. ↑
[151] Top ten UK’s hottest years all since 2002 - Met Office ↑
[152] Updated projections of UK heat-related mortality using policy-relevant global warming levels and socio-economic scenarios, Kenkins et al 2022.Updated projections of UK heat-related mortality using policy-relevant global warming levels and socio-economic scenarios — University of East Anglia (uea.ac.uk) ↑
[153] Infrastructure for charging electric vehicles: Approved Document S - GOV.UK (www.gov.uk). ↑
[154] The Authority will require applicants to demonstrate evidence of discussions with service providers and documentary evidence in relation to the cost effectiveness of providing connections via the submission of a Digital Infrastructure Delivery Plan. ↑
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