Non-Settlement Based Policies

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• Policy POSSTRI: Trinity Broads
• Policy POSSUT: Upper Thurne
• Policy POSSPUBS: Pubs network
• Policy POSSROADS: Main road network[183]
• Policy POSSTRACKS: Former rail trackways
• Policy POSSSTATIONS: Railway stations/halts
• Policy POSSSTAITHES: Staithes
• Policy POSSCOAST: The Coast
• Policy POSSMILLS: Drainage Mills
• Policy POSSLGS: Local Green Space
• Policy POSSA47: Road schemes on the Acle Straight (A47T)

Policy POSSTRI: Trinity Broads

Parishes affected.

Filby CP, Fleggburgh CP, Hemsby CP, Martham CP, Mautby CP, Ormesby St. Michael CP, Rollesby CP, Stokesby with Herringby CP.

Constraints and features

• Much of area in, variously, SAC, SPA, SSSIs, CWS, and/or LNRs.
• Flood risk and open water (zones 1, 2 & 3 by EA mapping; zones 1, 2, 3a & indicative 3b by SFRA 2017 mapping).
• Ormesby Water Works (see ORM1).

Reasoned Justification

This area of the Broads, although not alone in either tranquillity or nature value, is especially susceptible to change.

Essex & Suffolk Water abstracts more than five million litres of water (on average) a day from Ormesby Broad, which helps to supply more than 80,000 people in the Great Yarmouth area. Good water quality is vital to this role. The Trinity Broads are separated from the main navigation so there is an absence of through boat traffic, and access and ownership restrictions limit the number and type of craft (for example, petrol- and diesel-powered craft are prohibited except for safety vessels). These factors contribute to the special tranquillity of the area.  The Trinity Broads Project (a partnership of Essex & Suffolk Water, the Broads Authority, Natural England, Norfolk Wildlife Trust and the Environment Agency) has, over a period of 20 years, been highly successful in restoring and managing the biodiversity of the area, improving water quality, managing recreation, and involving local people.

When considering planning applications in this area, the Authority will consider if a trial period with a temporary planning permission and a funded programme of monitoring is appropriate or necessary. The specifics of a proposal could mean that a project level Habitats Regulation Assessment could be needed.

This area of the Broads in particular has dark skies. In accordance with policy PODM27, the darkness of the skies will therefore be maintained through addressing potential light pollution arising from proposals.

Reasonable alternative options

Considering the importance of the Trinity Broads and the constraints in the area and features of the site, the option of no policy is not considered reasonable.

No reasonable alternative options.

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. 1 ? Overall, positive.

How has the existing policy been used since adoption in May 2019?

According to recent Annual Monitoring Reports, the policy has not been used.

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Policy POSSUT: Upper Thurne

Parishes affected

Catfield CP, Hickling CP, Horsey CP, Ingham CP, Martham CP, Potter Heigham CP, Repps with Bastwick CP, Sea Palling CP, Somerton CP, Winterton-on-Sea CP.

Constraints and features

• Much of area in, variously, SAC, SPA, SSSI, CWS.
• Flood risk, including serious risk of coastal inundation (zone 3, with some zones 1 & 2, by EA mapping; zone indicative 3b by SFRA 2017 mapping).

Reasoned Justification

This area, although not alone within the Broads in either tranquillity or nature value, is especially susceptible to change. It is also likely to be in the forefront of climate change impacts.

It differs from most other parts of the Broads in that there are relatively low levels of boat traffic, in part because of the restriction to navigation of the bridge at Potter Heigham. The water quality is vulnerable to change, as limited water flow in this part of the network limits the dispersal of agriculture related pollution and the salinity arising from seawater intrusion through the ground. The Upper Thurne Working Group (made up of statutory, charity, user group and parish representatives) has, over a period of 20 years, been highly successful in restoring and managing the biodiversity of the area, improving water quality, managing recreation, and involving local people.

This area of the Broads in particular has very dark skies, with the majority of the area being the darkest in the Broads. In accordance with policy PODM27, the darkness of the skies will be maintained through addressing potential light pollution arising from proposals.

Reasonable alternative options

Considering the importance of the Upper Thurne and the constraints in the area and features of the site, the option of no policy is not considered reasonable.

No reasonable alternative options.

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. 1 ? Overall, positive.

How has the existing policy been used since adoption in May 2019?

According to recent Annual Monitoring Reports, the policy has not been used.

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Policy POSSPUBS: Pubs network

Parishes affected.

Acle CP, Beccles CP, Bramerton CP, Brundall CP, Burgh Castle CP, Burgh St. Peter CP, Cantley CP, Carleton St. Peter CP, Coltishall CP, Dilham CP, Fritton and St. Olaves CP, Geldeston CP, Halvergate CP, Hickling CP, Horning CP, Hoveton CP, Ludham CP, Ormesby St. Michael CP, Oulton Broad CP, Potter Heigham CP, Reedham CP, Rockland St. Mary CP, Rollesby CP, Somerleyton, Ashby and Herringfleet CP, Stalham CP, Stokesby with Herringby CP, Surlingham CP, Sutton CP, Thorpe St. Andrew CP, Thurne CP, Woodbastwick CP.

Constraints and features

• Almost all these premises are in zones of high flood risk.
• Some are in conservation areas, or areas of archaeological interest. Some are themselves of historic interest, including listed buildings.
• Some are within or close to SAC, SPA, SSSI, Ramsar, CWS, etc.

Reasoned Justification

The waterside pub network is very important, especially for recreational boating but also to local communities and non-boating visitors. While this can be said about a very wide range of establishments and locations public houses, for a variety of reasons, have been especially vulnerable to closure in recent years.

The loss of any particular pub (or other establishment) can sometimes be difficult to resist. Specifying in the Local Plan that these are part of a defined network will strengthen the planning case against any individual closure. It also signals the planning stance and helps owners and prospective developers get consistent messages about the identified establishments, to guide their own plans.

The policy seeks the retention of the pubs as public houses and supports appropriate improvements to the pub to make sure it remains viable. Such improvements could include the appearance of the pub as well as provision of specific facilities for water and road users (such as canoe slipways and well-designed and located Sheffield Stand cycle parking). Indeed, applicants should consider water safety provisions as part of their schemes.

The policy also addresses the issue of drainage, due to the seasonality, proximity to the watercourse, and the nature of the effluent that can pose a significant local risk to the water environment. Ensuring there is no deterioration in water quality is an important requirement under the Water Framework Directive, which applies to all surface water bodies and groundwater bodies.

As set out in policy PODM27, addressing light pollution in the Broads is an important aspect of the Local Plan. These establishments can be in rural areas, sometimes away from or on the edge of settlements, and any external lighting can have a significant impact on the tranquillity of the area. Proposals therefore need to address light pollution.

Many of the pubs are historic assets or have an impact on the landscape or townscape, which is another reason people go to them. The policy seeks to recognise this. For example, when historic pubs have their historic value eroded through inappropriate alterations such as upvc windows/ loss of architectural detailing/unsympathetic hardstandings, it can be detrimental to both their heritage value but also their attractiveness to customers.

Delivery of policy

In cases where owners wish to pursue other forms of use of the public houses, they will be required to submit a report undertaken by an independent Chartered Surveyor, which meets the tests as set out in the CAMRA Public House Viability Test,^[180] with any planning application. The Authority will need to verify the content of the report and may need to employ external expertise to do so (the applicant will need to meet the cost of this). The Broads Authority’s Viability and Marketing Guide^[181] will also be of relevance. The Broads Authority’s Viability and Marketing Guide^[182] will also be of relevance.

In relation to addressing any issues relating to crime, the Licensing Security and Vulnerability Initiative may be of relevance. Licensing SAVI is a confidential self-assessment tool designed to help the owners and operators of licensed premises provide a safe and secure environment for their managers, staff, customers and local communities - https://www.licensingsavi.com. Furthermore, pub owners may want to consider their parking areas meeting this standard: ParkMark - Home.

Reasonable alternative options

No policy on pubs - An alternative option could be to have no specific policy relating to pubs; any application would be considered using existing policies.

Another option would be to not amend the policy in relation to light pollution, efficiency or historic and architectural assets.

Sustainability appraisal summary

The following is a summary of the assessment of the policy and alternative(s).

A: No policy: Not having a policy does not mean that these issues will not be considered or addressed. A policy does however provide more certainty.

B: Keep original policy (other than updating the pub names): 7 positives. 0 negatives. 1 ? Overall, positive.

C: Preferred Option - amend policy to improve reference to light pollution (and update pub names): 10 positives. 0 negatives. 1 ? Overall, positive.

How has the existing policy been used since adoption in May 2019?

According to recent Annual Monitoring Reports, the policy has been used and applications have been determined in accordance with the policy.

Why have the alternative options been discounted?

The pubs in the Broads are so important to the community, visitors and local economy. Pubs, for a variety of reasons, are at risk if being lost. This policy seeks to ensure the continued existence of the pubs in the Broads whilst promoting/enabling appropriate changes to ensure the long-term viability of the pubs. As such, it seems prudent to continue to have this policy in the Local Plan. In terms of preferring the slightly amended policy, this will strengthen the protection of dark skies as often, these pubs are directly on waterways in rural or edge of urban areas where lighting, if installed incorrectly or excessively, can cause light pollution. The amendments also cover issues such as water and energy efficiency which are important given the cost of living rise, climate change and water resource issues. The amendments relating to the pubs being assets is preferred as in some cases, the building itself is an attraction and asset to the area.

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Policy POSSROADS: Main road network^[183]

Parishes affected.

Acle CP, Beccles CP, Broome CP, Bungay CP, Coltishall CP, Ditchingham CP, Filby CP, Fleggburgh CP, Fritton and St. Olaves CP, Gillingham CP, Haddiscoe CP, Halvergate CP, Hoveton CP, Horning CP, Ludham CP, Mautby CP, Potter Heigham CP, Repps with Bastwick CP, Ormesby St. Michael CP, Rollesby CP, Smallburgh CP, Stalham CP, Upton with Fishley CP, Wroxham CP.

Constraints and features

• Some of these routes are within or close to SAC, SPA, Ramsar sites, or SSSIs.
• Routes pass through high flood risk zones.

Reasoned Justification

The highway authorities and Norfolk and Suffolk County Councils have recommended that the Authority continues protecting these routes from any development that undermines their wider purpose or highway safety. The routes can be found here:

• In Norfolk see www.norfolk.gov.uk/what-we-do-and-how-we-work/policy-performance-and-partnerships/policies-and-strategies/roads-and-travel-policies/transport-asset-management-plan in particular map ciii of the appendices.
• In Suffolk Part 1 of the Suffolk Local Transport Plan has a principal routes diagram on page 35: www.suffolk.gov.uk/roads-and-transport/transport-planning/transport-planning-strategy-and-plans and there is also the Suffolk Lorry Route network: Recommended Lorry Route Network Map.

Where development may have transport impacts it should be supported by an appropriate level of survey and assessment to inform the decision-making process. Transport Statements or Transport Assessments are used to assess the potential impact of a development. See policy PODM28.

The need for and level of formal transport assessment will be determined in consultation between the developer and the relevant authorities (Local Planning Authority, Local Highways Authority, Local Transport Authority and National Highways) (see policy PODM28). In cases where the development may also impact upon the Trunk Road network (A12 and A47), discussions should also take place with National Highways, who has a responsibility to maintain the Trunk Road network on behalf of the Secretary of State^[184].

Also of relevance is Policy POSSA47 on the Acle Straight.

Reasonable alternative options

No policy

The original policy, with no amendments.

Sustainability appraisal summary

The following is a summary of the assessment of the policy and alternative(s).

A: No policy: 0 positives. 0 negatives. 2 ? Overall, positive.

B: Keep original policy: 2 positives. 0 negatives. 0 ? Overall, positive.

C: Preferred Option - amend policy: 2 positives. 0 negatives. 0 ? Overall, positive.

How has the existing policy been used since adoption in May 2019?

According to recent Annual Monitoring Reports, the policy has not been used.

Why has the alternative option been discounted?

The amended policy is preferred because it provides clarification and makes the policy more consistent with the NPPF.

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Policy POSSTRACKS: Former rail trackways

Constraints and features

• Flood risk (zones 2 & 3 by EA mapping; zone 2, 3a/indicative 3b and modelled 3b by SFRA 2017 mapping).
• Parts within Beccles Marshes Suffolk County Wildlife Site and adjacent to SPA, SAC and Ramsar site.

Reasoned Justification

The routes are:

• Haddiscoe to Beccles
• Beccles to Ditchingham
• Great Yarmouth to Fritton

The Broads Integrated Access Strategy has identified the potential that remnant disused railway lines can add to the access provision in the Broads, particularly for improving cycle route links and bridleway routes - there are only 17km of bridleways in the Broads Authority Executive Area. Establishing routes for walkers, cyclists, and horse riders on these disused railways, which are linked to the rural road network, would improve opportunities for recreation and enjoyment of the Broads. Cycling will help deliver the Government's cycling ambition in the National Parks Programme.

The recreational potential of these routes (or parts of them) has long been noted, and Norfolk and Suffolk County Councils support their protection for these purposes. In view of the importance of recreation to the Broads, including the statutory purpose of enjoyment, and the desirability of developing the tourism and recreational potential of the southern Broads, these routes are protected.

These routes are no longer protected for future rail use. Both County Councils, as the transport authorities for the area, have advised there is no realistic prospect of this happening in the foreseeable future.

It is important to note that sections of these routes are outside the Broads Authority Executive Area. The relevant authorities have been asked to consider protecting the routes in their Local Planning Authority areas, in a similar way to this policy.

Such routes will benefit from the presence and proximity of wildlife and habitat associated designations but will need to have regard to such sensitivities in route creation, alignment, and management.

The impact of changes to the landscape of the Broads is also an important consideration.

The Authority would welcome well-designed art and interpretation - see policy PODM12 on linking to the past. However, signage and interpretation should only be that necessary to promote and direct along the route and should not impact on the landscape of the Broads (see policy PODM20).

Reasonable alternative options

No policy

Original policy

Sustainability appraisal summary

The following is a summary of the assessment of the policy and alternative(s).

A: No policy: 5 positives. 0 negatives. 0 ?

B: Original policy: 5 positives. 0 negatives. 0 ? Overall, positive.

C: Preferred Policy (amended): 5 positives. 0 negatives. 0 ? Overall, positive.

How has the existing policy been used since adoption in May 2019?

According to recent Annual Monitoring Reports, the policy has not been used.

Why have the alternative options been discounted?

These routes have great potential in providing access and recreation routes for walking, cycling and horse riding. Perhaps the routes may not be at risk from development, but having a policy shows the intention clearly as well as ensures protection of these routes from any unforeseen development. The amended policy is preferred because it emphasises how any proposed development can deliver part of the route for recreation uses.

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Policy POSSSTATIONS: Railway stations/halts

Constraints

• Flood zone 2 and 3 (EA Mapping) and indicative 3b by SFRA 2017 mapping (except Hoveton and Wroxham Station)
• Buckenham Station: near to Mid Yare National Nature Reserve, Broadland Ramsar Site, Yare Broads and Marshes SSSI, The Broads SAC, Broadland SPA.
• Berney Arms Halt: Halvergate Marshes SSSI, Breydon Water SPA, Breydon Water Ramsar Site

Reasoned Justification

There are five railway stations/halts (or parts of) within the Broads Authority Executive Area, and these are shown on the policies map.

While some stations are used more than others, all are important to the local community and visitors. The more remote stations or halts offer a unique opportunity for visitors to access the wilder parts of the Broads without the need of a private car.

Some of the stations/halts are part of a network of historic railway stations. They have heritage and architectural value and are good examples of railway architecture. Our historic environment/heritage asset policies will be used to ensure protection and preservation of assets or seek to reinstate historic features as appropriate.

The policy seeks retention of railway stops and supports appropriate improvements to the facilities that reflect, but do not impact on, the special qualities of the Broads. In particular, in line with policy PODM14, proposals will be expected to provide biodiversity enhancements, as appropriate. And given that some stations/halts are isolated or on the edge of built-up areas, lighting can have a big impact on the area and so particular care and attention will be given to any lighting.

Regarding improving access by sustainable modes of transport, example improvements could include the provision of well-designed and located secure cycle parking facilities and electric charging points for electric vehicles.

Reasonable alternative options

No policy on stations/halts - an alternative option could be to have no specific policy relating to stations/halts; any application would be considered using existing policies.

Another option would be to not amend the policy in relation to light pollution and biodiversity enhancements.

Sustainability appraisal summary

The following is a summary of the assessment of the policy and alternative(s).

A: No policy: Not having a policy does not mean that these issues will not be considered or addressed. A policy does however provide more certainty. With stations/halts an essential element to the tourist network in the Broads it seems prudent to have a policy. As such, not having a policy was discounted.

B: Keep original policy: 5 positives. 0 negatives. 0? Overall, positive.

C: Preferred Option - amend policy to improve reference to light pollution and biodiversity enhancements: 8 positives. 0 negatives. 0?Overall, positive.

How has the existing policy been used since adoption in May 2019?

According to recent Annual Monitoring Reports, the policy has not need used.

Why have the alternative options been discounted?

The stations/halts in the Broads are so important to the community, visitors and local economy. This policy seeks to ensure the continued existence of the stations/halts in the Broads whilst promoting/enabling appropriate changes to ensure their long-term viability. As such, it seems prudent to continue to have this policy in the Local Plan. In terms of preferring the slightly amended policy, this will strengthen the protection of dark skies as often, these stations/halts are in rural or edge of urban areas where lighting, if installed incorrectly or excessively, can cause light pollution. Indeed, given their location, and given the importance of biodiversity recovery, the amended wording relating to biodiversity enhancements is preferred.

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Policy POSSSTAITHES: Staithes

Reasoned justification

A staithe (as defined in the 1988 Broads Act) means any land that is adjacent to a waterway and that the inhabitants of the locality are entitled to use as a landing place. A staithe is for loading and unloading.

There have been several instances where staithes have been adversely possessed by individuals, for example being fenced off, or claimed as an individual’s property. By losing staithes, there is a negative impact on public access to the water as well as use of the staithes for loading. The Broads Act 1988 sets powers on the Broads Authority to protect the existence of staithes and the ability of the public to use and access them (Part 2, section 37).

Reasonable alternative options

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: No policy: 0 positives. 0 negatives. 6 ?

How has the existing policy been used since adoption in May 2019?

According to recent Annual Monitoring Reports, the policy has been used and applications have been determined in accordance with the policy.

Why has the alternative option been discounted?

An alternative option is to not have a policy. If this option were to be taken forward, there would be no protection for staithes through the planning process. This is deemed an unreasonable option and has not been taken forward for consideration. This is because the policy is in the current Local Plan and there have not been any suggestions to remove it. Also, fundamentally, the policy provides a level of protection for staithes, which are important locally.

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Policy POSSCOAST: The Coast

Parishes affected.

Horsey CP, Winterton-on-Sea CP.

Constraints and features.

• Wholly in SAC and SSSI, partially within SPA. Adjacent CWS.
• Part of area within the Norfolk Coast Area of Outstanding Natural Beauty (AONB).
• Article 4 Direction (1964) covering most of area removes permitted development rights for caravanning and camping, etc.
• High risk of tidal inundation from a breach of the coastal defences (Environmental Agency work ongoing to model such a breach).
• High risk of flooding (flood zone 3) (EA mapping), riverine flood risk (zone 3 by EA mapping; zone indicative 3b by SFRA 2017 mapping).
• EA have undertaken considerable work to maintain sea defences.
• Part of the England Coast Path.
• Risk of coastal erosion.

Reasoned Justification.

The coastal area of the Broads has a very special character and tranquillity, and wildlife and landscape importance. It is highly valued for walking and for bird and seal watching. It is also particularly vulnerable to climate change and sea level rise and has been subject to sporadic coastal inundation for centuries (it was once the river mouth), with parts at risk of riverine flooding. This area of coast is also vulnerable to coastal erosion.

The area is generally unsuitable for development because of these flood risk, wildlife, and landscape issues. The policy reinforces this and clarifies the general approach to the area’s use and the limited types of development likely to be appropriate.

The Environment Agency highlights the high risk of tidal inundation in the event of a breach of the coastal defences.

This policy approach is consistent with the vision, objectives, and policies of the AONB Management Plan Strategy^[185] (2019-2024) and with the UK vision for the marine environment for ‘clean, healthy, safe, productive, and biologically diverse oceans and seas’.

In line with policy PODM27 on light pollution, the area has very good quality dark skies, which will be maintained.

According to the Shoreline Management Plan, as a summary of this document, the general approach to coastal erosion along this stretch for the present day and medium term is to hold the line up to 2055. This is dependent on the option continuing to be technically and economically deliverable, and over time, other options may be investigated such as possible managed realignment, or a retired line of defence further inland. In relation to the present day, the plan says: ‘due to the considerable assets at risk and the uncertainty of how the coastline could evolve, the policy option from the present day is to continue to hold the line of the existing defence. This policy option is likely to involve maintenance of existing seawalls and reef structures, replacing groynes as necessary and continuing to re-nourish beaches with dredged sand. This policy option will provide an appropriate standard of protection to all assets behind the present defence line, and, with the recharge, a beach will be maintained as well as a supply of sediment to downdrift areas.’

The Authority, working with neighbouring coastal authorities, has produced the Coastal Adaptation SPD (2023). The Coastal Adaptation Supplementary Planning Document (SPD) provides guidance on policy approaches along the coast from Holkham in Norfolk to Landguard Point, Felixstowe in Suffolk. The SPD supports the implementation of Local Plan polices, provides case study examples of coastal adaptation best practice and will:

• Ensure Coastal Communities continue to prosper and can adapt to coastal change; and
• Provide detailed guidance for developers, landowners, development management teams, and elected members on the interpretation of policies with a whole coast approach.

Reasonable alternative options

No policy

Sustainability appraisal summary

The following is a summary of the assessment of the policy and alternative(s).

A: Policy – Preferred Option: 5 positives. 0 negatives. 0 ? Overall, positive.

B: No policy: 0 positives. 0 negatives. 5 ?

How has the existing policy been used since adoption in May 2019?

According to recent Annual Monitoring Reports, the policy has not been used.

Why have the alternative options been discounted?

Given the undeveloped nature of the small stretch of the coast within the Broads and this being a special place for people and wildlife, to have a policy is favoured.

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Policy POSSMILLS: Drainage Mills

Constraints and features

• The mills are all either listed buildings or on the Local List.
• Many of the mills are:
  • in Conservation Areas.
  • in SAC, SPA, Ramsar, CWS, etc and their zones of influence.
  • In nutrient neutrality areas.
• Most of the mills are:
  • at high risk of flooding.
  • In dark areas of the Broads.

Reasoned Justification

Drainage mills are a defining feature of the historic landscape of the Broads and contribute significantly to its landscape character, viewed from both land and water. The mills tend to be the largest and most obvious structures in the flat, open landscape and are often located in groups of significant visual amenity to the Broads. The mills vary in size and design, but all had the fundamental purpose of draining water from the land to enable the fields to be grazed and latterly to be used for other agricultural uses. They therefore contribute to our understanding of the Broads’ cultural heritage.

Of the approximately 80 standing mills in the Broads, about 50 are listed and the rest are locally listed. Many mills are intrinsically historically significant and contain machinery that represents innovation or is the last example of technology.

Redundancy, exposure to elements and vulnerability to vandalism mean several of the mills are recorded locally and nationally as being ‘at risk’. Halvergate Marshes Conservation Area, which contains many of the drainage mills, is the only Conservation Area in the Broads that is ‘at risk’ and is included on Historic England’s Heritage at Risk Register.

A significant number of the mills are neglected and require repair. Due to their remote locations with limited access, usually in areas at risk of flooding, proposals for restoration are not easy to develop and can be costly.

The policy encourages the repair and restoration of standing mills. In cases where there are archaeological remains only, the relevant local and national policies will apply.

However, some mills are now mainly of landscape value; these mills are in a particularly vulnerable or fragile condition and could potentially be lost to the Broads’ landscape. The consolidation and repair of these mills is encouraged to ensure that they can continue to contribute to the landscape.

In some cases, it may be acceptable to seek alternative uses for mills, to ensure that the structure is repaired and has a sustainable future. It is likely that these mills will be more accessible and may be of less historic significance with little or no internal machinery.

In such cases, re-use may be appropriate, as long as the positive landscape contribution of such mills is retained, their setting and significance is preserved and enhanced through their creative conservation and alterations do not cause harm to the historic fabric (and other planning policy requirements, for example in relation to flood risk, are met).

Where an alternative use is not considered acceptable (for example, where a listed mill retains its original fabric, machinery and character and harm may be caused to its significance through a change of use), it may be appropriate to secure the repair of listed mills through enabling development. This will only be permitted where it will secure the long-term conservation of a designated heritage asset at risk, where this can only be achieved through enabling development and when the proposal complies with the Historic

England guidance on Enabling Development. The timing and repair of the mill and any associated structures would be secured via a Section 106 Agreement or planning obligation.

This policy gives a general framework to guide decisions. As set out above, what is appropriate for one mill will not be for another, and expert advice will be required to help assess applications for changes to mills.

The Environment Agency highlights the potential need for a range of consents, to avoid adverse impacts on fish, flooding, and water flows.

The re-use of historic buildings policy (PODM13) and conversion of buildings policy (PODM61) may also be of relevance to proposals for mills. Further, to reflect that mills tend to be in isolated, rural areas, proposals will need to meet the requirements of policy PODM27 in relation to light pollution.

The policy highlights that, depending on the proposals, the scheme may also need to mitigate recreation impacts, and this is most easily done through paying the GI RAMS tariff. Depending on the type of scheme and the location of the mill, the impact of the scheme on nutrient enrichment may need considering.

Reasonable alternative options

An alternative option would be to keep the original policy.

No policy

Sustainability appraisal summary

The following is a summary of the assessment of the policy and alternative(s).

A: Keep original policy: 4 positives. 0 negatives. 0 ?

B: Preferred Option – amended policy: 7 positives. 0 negatives. 0 ?

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 were in conformity.

Why has the alternative option been discounted?

Given the importance of mills to the area, not to have a policy is not the preferred approach. The changes reflect lessons learned over the last few years and help make the policy clearer, stronger and improves the protection of the mills and is therefore favoured.

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Policy POSSLGS: Local Green Space

Reasoned Justification

Local green spaces are green spaces that are demonstrably special to a local community. The preparation of local and neighbourhood development plans offers the opportunity to designate local green spaces and provide extra protection to them that rules out new development other than in very special circumstances.

Local green space must be reasonably close to the community it serves; have demonstrable local significance and interest; be local in character; and not cover an extensive tract of land.

The Broads’ community was asked to nominate areas to be considered as local green space. The Local Green Space Map Bundle and the following list show the spaces allocated as areas of local green space:

• Bridge Green, Potter Heigham
• Chedgrave Common and Chedgrave Carr
• Part of Waveney Meadow that is not open space, Puddingmoor, Beccles
• Land surrounding Beccles Rowing Club, Off Puddingmoor, Beccles
• The Stone Pit, Station Road, Geldeston
• The playing field, Station Road, Geldeston

As part of this review of the Local Plan for the Broads, a call for sites for areas of Local Green Space was held (end of 2022), and three new sites were put forward. The Parish Councils relevant to the Local Green Spaces allocated in the 2019 Local Plan for the Broads were contacted to ascertain if they wanted the status to continue. The analysis of local green spaces can be found in the Local Green Space Topic Paper.

Please note that there are other areas of Local Green Space that are relevant to the Broads, allocated in various Neighbourhood Plans. The policies maps may show some of these Neighbourhood Plan Local Green Spaces.

The 2023 NPPF at paragraph 107 says that‘policies for managing development within a Local Green Space should be consistent with those for Green Belts’.The 2023 NPPF goes on to say that inappropriate development can harm green belt (and therefore local green space) and should only be approved in very special circumstances (para 152 and 153). The 2023 NPPF then goes on to provide clarification of this by saying‘Very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm resulting from the proposal, is clearly outweighed by other considerations.

Reasonable alternative options

The original policy, with no amendments.

Considering there are current Local Green Spaces and also nominations for more Local Green Spaces, not to have a policy is seen as not a reasonable alternative.

Sustainability appraisal summary

The following is a summary of the assessment of the policy and alternative(s).

A: Keep original policy: 3 positives. 0 negatives. 0 ? Overall, positive.

B: Preferred Option - amend policy: 3 positives. 0 negatives. 0 ? Overall, positive.

How has the existing policy been used since adoption in May 2019?

According to recent Annual Monitoring Reports, the policy has not been used.

Why have the alternative options been discounted?

The amendments to the original policy fundamentally reinforce the importance of these Local Green Spaces and how proposals on and around them will be considered.

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Policy POSSA47: Road schemes on the Acle Straight (A47T)

Constraints and features

• Entire length of Acle Straight in Flood Zone 3 (EA mapping) and indicative 3b using SFRA 2017 mapping.
• Western end: Damgate Marshes SSSI, Halvergate Marshes SSSI, Broadland SPA, Broadland Ramsar site and The Broads SAC.
• Eastern end: Breydon Water LNR, SSSI, Ramsar Site, SPA, Outer Thames Estuary SPA.
• Stracey Arms Drainage Mill (listed building) is next to the Acle Straight.
• Other listed buildings in proximity to the Acle Straight.
• Halvergate Marshes Conservation Area (currently on Historic England’s Heritage at Risk Register).
• The Broads is a site identified by Historic England as having exceptional potential for waterlogged archaeology.
• Undesignated heritage assets that contribute to the cultural heritage of the area, such as the WW2 defences and assets identified on the Norfolk HER and Broads Local List.
• Numerous accesses to tracks, for example to farms.
• Numerous level crossings accessed from the Acle Straight.
• Branch Road junction.
• Little Whirlpool Ramshorn Snail (Anisus vorticulus) is a habitat site.
• The Acle Straight runs in between railway line and river.
• Open and flat landscape.
• Historic dyke networks with associated features.
• Rights of Way.
• Users of the Acle Straight experience congestion regularly.
• Serious accidents on the Acle Straight are higher than the national average (13%) and the average for Norfolk County (16%).
• Peat soils.
• Grade 1 agricultural land to the east
• Grade 3 agricultural land for the most part

Reasoned justification

Background to the A47 and Acle Straight

The A47 Trunk Road passes through the Broads Authority area and this policy relates to the section of the A47 between Acle and Great Yarmouth, known as the Acle Straight.

The A47 is the main east-west connection in northern East Anglia. It links Lowestoft to Great Yarmouth and then with Norwich, King’s Lynn and Peterborough to the A1, with connections to the Midlands and the north of England. At Great Yarmouth and Norwich, connections to Europe and beyond are available via the port and airport. New Anglia Local Enterprise Partnership’s Economic Strategy considers this route of strategic importance.

The Acle Straight is a single carriageway with at-grade roundabouts at each end. This section of the A47 has high vehicle flows including a high use by HGVs resulting in longer and more unreliable journey times, as well as delays and congestion at junctions. The two-way Annual Average Weekday Flow (AAWF) on the A47 at Acle Straight is approximately 21,000 vehicles, including a significant HGV percentage of more than 17% in the AM peak period.

Over the last five years (to end October 2023) there were 74 collisions recorded on the Acle Straight, of which 3 were fatal and 16 resulted in serious injuries. National Highways identified in their Route Strategy for the East of England that the Acle Straight has an iRAP star rating of 1^[186] (2020). The higher the rating, the safer the road.

Accidents on the Acle Straight have also resulted in road closures, with traffic having to be diverted onto unsuitable alternative routes. Incident records show that the greatest delays in the area occur due to accidents, with the average delay exceeding over two hours.

What could happen to the Acle Straight and why?

There is an ambition promoted by the A47 Alliance to dual the A47 for its full length, including the stretch between Acle and Great Yarmouth. The A47 Alliance brings together the business community, local authorities, MPs and stakeholders along the whole of the trunk road route between Peterborough and Lowestoft. Partners, including the Greater Cambridge, Greater Peterborough and New Anglia LEPs are working together to make the case for improvements and to secure the investment required to make it happen.

In 2014, Government committed to funding six A47 dualling and improvement schemes, one of which was improvements to the Great Yarmouth Harfreys and Vauxhall junctions. Works have begun at Harfreys Roundabout, tying into the Great Yarmouth Third River Crossing. Surveys have been undertaken in preparation for the Vauxhall Roundabout improvement scheme which is still being developed.

The Authority acknowledges that changes to the Acle Straight could bring benefits in relation to road safety, improved management of surface water and pollutants, and the economy of the local area in particular economic growth of the sub-region of Great Yarmouth and Lowestoft and wider region^[187] through reduced congestion and delays and more reliable journey times. There are also opportunities associated with schemes as mentioned in the policy, such as the potential for archaeological finds, a new route alongside a dualled road, and potential for interpretation of the Broads.

Determining applications relating to the Acle Straight

The Broads Authority would not determine any future planning application for dualling the Acle Straight. The scheme is likely to be determined as a Nationally Significant Infrastructure Project (NSIP) by the Planning Inspectorate, because the developable area could be over 12.5Ha and because the scheme could have environmental impacts^[188] .

There is a possibility that the dualling of the Acle Straight will come forward during this Local Plan period and the purpose of this policy is to identify important issues and considerations in determining the suitability of any proposal.

Major Development

Some changes to the Acle Straight may be considered as Major Development for the purposes of the 2023 NPPF paragraphs 176 and 177 (and footnote 60) and policy PODM1 of this Local Plan which addresses major development in the Broads.

The Acle Straight and the Broads

The first statutory purpose of the Broads Authority is conserving and enhancing the natural beauty, wildlife and cultural heritage of the Broads. Section 17A of The Norfolk and Suffolk Broads Act 1988 imposes a statutory duty on authorities to seek to further the relevant statutory purposes when exercising their functions that can affect land in the Broads. For the avoidance of doubt, the special qualities of the Broads are those set out at section 7.14. Furthermore, of particular importance and relevance in understanding the impacts of any scheme are the Broads Landscape Sensitivity Study and Broads Landscape Character Assessment. Areas 19, 24, 25 and 20 of these studies are the relevant areas for consideration.

The Authority acknowledges that schemes will be designed to national guidance and requirements; the policy and the following information highlights and explains locally important criteria that need addressing in any scheme. It is considered that the clear guidance the policy and supporting text provides will assist in the development and design of any future scheme.

Fundamentally, because of the potential adverse impacts that changes to the highway schemes/changes to the Acle Straight may have on the landscape, visual amenity, historic environment, ecology, habitats, access and special characteristics of the Broads, of either a temporary or permanent nature, any changes to the Acle Straight will need to be designed to reduce and avoid such impacts in the first place. Only then can mitigation be considered. These specific criteria need to be considered and addressed as part of any scheme.

Wildlife and habitats

The Broads is one of the nation’s richest areas for biodiversity, with habitat sites and designated habitats and species flanking and occupying the habitats close to the existing road. European and nationally protected species such as water vole, bat and otter are likely to be impacted by any changes. Water voles have suffered drastic declines across the country in recent years, although populations in the Broads are still high. Any loss of water vole habitat in the ditches would need to be compensated and water vole populations translocated.

Any increase in lighting could potentially cause adverse impacts on bat populations in the area. Light pollution is known to deter bats from commuting and foraging areas, delay their emergence for hunting and cause disturbance to roosts.

The area is already a significant site for otter mortality. Road widening risks making this worse, so the Authority would expect changes that underline the need to include enhancements, such as wildlife crossing points. Other impacts on wildlife, such as increased barn owl road fatalities, would also need to be addressed.

Many of the grazing marsh ditches hold conservation designations of European importance, supporting important plant and invertebrate communities. Any impacts to the ditch network would need to address this loss, considering alternatives, mitigation (including translocation), compensation, long-term conservation and monitoring.

One of the already specified issues that changes to the Acle Straight would need to address is the Little Whirlpool Ramshorn Snail. The dykes around the current road are one of the few habitats of this species, which is on an international ‘red list’ of endangered species. It is a small aquatic snail with a flattened spiral shell of approximately 5mm in diameter. It has been declining from the UK since the 1960s, although the reason for the decline is not clear. A study investigating the potential to translocate the snail (AECOM, March 2015) concluded that translocation was a potential option, but identified various considerations such as:

• Pathogen transference has been highlighted as an issue, and as such receptor and donor sites should derive from the same drainage unit.
• Donor sites must have a robust population and only sites with no current population should be used as receptor site.
• In order to ascertain these sites and to increase knowledge of the target species, robust
  pre-translocation survey is a necessity.
• In addition, receptor sites will need to be properly assessed to ensure the receiving habitat is suitable.

Large-scale changes such as dualling the Acle Straight are likely to result in the loss of habitat, as the surrounding dykes could be lost, as could some marshland. The Authority would expect any loss to be avoided and then minimised, with compensation likely to be required. Areas requiring compensation include the need to secure land purchase, conservation management or long-term covenants for defined enhancements, and monitoring regimes. In the first place a scoring system for compensation should be worked up by independent consultant and agreed by all parties.

Landscape and tranquillity

Another key issue is the impact of changes to the road on the landscape character of the Halvergate Marshes Conservation Area. The A47 crosses an area known as the Halvergate marshes or Halvergate triangle. This area forms one of the defining landscapes of the Broads Authority Executive Area, being a vast panoramic expanse of grazing marsh dotted with windmills and often teaming with wildlife. The sheer scale, inaccessibility and emptiness of much of the marshland means it remains largely quiet and isolated. It is designated as a Conservation Area and its biodiversity interest is recognised through national and international designations. The dualling of the Acle Straight has the potential to cause significant adverse effects to both the existing landscape character of the area (including tranquillity through increased traffic noise) and nature conservation interests.

Notwithstanding the above, it is recognised that the current use of the road, which is often characterised by congestion, does not always positively contribute to a sense of tranquillity in the area and improvements to the road which better facilitate the movement of traffic could potentially result in benefits to tranquillity in the area.

Proposed highway options are likely to range in scale, nature and extent. A number of key characteristics have the potential to be affected through changes to the highway/schemes, through both the construction phase and as a result of the completed project. The significance of the effects on the landscape and visual amenity of the area (adverse or beneficial) of any option proposed will need to be assessed in accordance with current guidelines. Reference will need to be made to the current landscape character assessments for Local Character Areas 19, 24, 25 and 20 and the Conservation Area appraisal.

Dualling of the Acle Straight has the potential to cause significant adverse effects on the existing landscape character. Mitigation of these effects may be challenging and would need to recognise that common methods such as screening tree belts may be highly intrusive in terms of the extensive open landscape character.

Noise is an important aspect of tranquillity. Schemes should seek to address this, but the provision of noise barriers would be detrimental to the iconic landscape viewing potential along this route. There could be scope for low noise surfacing.

Surface water

Changes to the Acle Straight could result in more impermeable surfaces, leading to a greater volume of surface run off to wash more pollutants off the road surface. The sensitive habitats nearby could be adversely affected by pollutants.

Any changes to the Acle Straight would need to address increased risk of flooding at that point and elsewhere by implementing sustainable drainage or SuDS, and by considering potential hazard to water quality from the surface runoff. Water may require additional treatment prior to disposal and adequate steps need to be put in place. Where any SuDS are proposed, it is important to demonstrate that the SuDS hierarchy (see policy DM6) has been followed both in terms of:

• Surface water disposal location, prioritised in the following order: disposal of water to shallow infiltration, to a watercourse, to a surface water sewer, combined sewer / deep infiltration
  (generally greater than 2m below ground level); and
• The SuDS components used within the management train (source, site and regional control).

The CIRIA SuDS Manual C753 (2015) looks at designing sustainable surface water drainage from highways and designing for water quality issues.  Additional measures to address accidental spills will also need to be considered.

The Acle Straight is almost entirely within an Internal Drainage Board (IDB) area and the Water Management Alliance should be consulted at an early stage.  If infiltration is not favourable, they should be consulted to establish if surface water drainage discharge to a managed network would require consent.

The Environment Agency should also be consulted with regard to water quality and any particularly sensitive receptors nearby as well as in relation to strategic flood risk and any mitigation required to compensate for any floodplain affected. The Environmental Permitting (England and Wales) Regulations 2010 may be of relevance as well.

Light pollution

The Authority’s Dark Sky Report (2016) shows that the Acle Straight has good quality dark skies, with the western end in particular having very good quality dark skies^[189] . Any schemes need to be assessed in line with policy PODM27 Light pollution and dark skies.

Walkers, cyclists and horse riders

Changes to the Acle Straight offer the opportunity to improve provision for walkers, cyclists and horse riders and provide new facilities. The Broads Integrated Access Strategy has an aim for a shared use path along the length of the Acle Straight, which would provide a new link to enable non-car journeys between Acle and Great Yarmouth.

Interpretation and appreciation

The route is a tourist route as well an access route. Changes to the Acle Straight could include provision of parking laybys, allowing people the opportunity to appreciate the iconic landscape. The Authority would expect these areas to have no impediment to the view, and to provide interpretation points that would add to the visitor experience of the Broads.

Heritage assets

The listed Stracey Arms Drainage Mill is located immediately adjacent to the Acle Straight. The impacts of changes on this heritage asset will need to be addressed. There are many other intervisible (seen from each perspective) drainage mill structures, both nationally and locally listed, collectively forming the largest grouping in the UK. All of them contribute to the historic character of the drained marshland. The Norfolk HER contains many records relating to the area both in terms of archaeology and built form, an example being the World War 2 defences that remain in situ on the marshes.

The special historic interest of Halvergate marshes is particularly significant as a constantly evolving cultural landscape. That evolution is illustrated by numerous remnant structures, landscape and archaeological features, that collectively contribute to the historic significance of the area. Historic England has recognised this significance in terms of undiscovered archaeology and identified the Broads as an area of exceptional potential for waterlogged heritage. See policy PODM12 Heritage Assets, which relates to archaeology.

Virtually the whole of the Acle Straight corridor lies within the Halvergate Marshes Conservation Area, a designated Heritage Asset characterised by the cultural landscape and the features within it. A partnership project sponsored by the Heritage Lottery Fund has made a significant investment in works to restore the mills in the area and thereby enhanced the landscape.

The Authority would expect that the historic significance, including the potential archaeological significance of the area, is fully assessed and analysed in any proposal for changes to the Acle Straight. The historic environment is a finite resource and once lost cannot be replaced. The Authority therefore expects that any adverse impact on the historic environment, either built, landscape or archaeological, is kept to an absolute minimum, and that any adverse impact resulting from change is fully assessed and can be justified in line with the tests set out in section 16 of the 2023 NPPF. Where justification for harm can be made, any impact or harm should be mitigated, including improvements to existing features.

Practicalities

The current route has various pinch points bounded by river on one side and railway on the other. Further, numerous farm accesses and the road towards Halvergate will need to be accommodated. This may mean that any scheme cannot be fitted ‘on-line’ and a wider route choice corridor has to be considered. This could have immense implications on the landscape, heritage and ecology and could alter the attitude of the Authority to any proposals. Constraint scoping needs to be undertaken very early in the process.

Reasonable alternative options

No policy

The original policy, with no amendments.

Sustainability appraisal summary

The following is a summary of the assessment of the policy and alternative(s).

A: No policy. 0 positives. 0 negatives. 9 ?

B: Keep original policy. 8 positives. 0 negatives. 0 ? Overall, positive.

C: Preferred Option - amend policy. 9 positives. 0 negatives. 0 ? Overall, positive.

How has the existing policy been used since adoption in May 2019?

According to recent Annual Monitoring Reports, the policy has not been used.

Why has the alternative option been discounted?

The amended policy is preferred because it provides clarification and emphasises the properties and importance of peat.

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• [180] CAMRA Public House Viability Test: https://pubs.camra.org.uk/dl.php?id=57295↑

• [181] https://www.broads-authority.gov.uk/__data/assets/pdf_file/0019/407404/Marketing-and-Viability-SPD.pdf↑

• [182] https://www.broads-authority.gov.uk/__data/assets/pdf_file/0019/407404/Marketing-and-Viability-SPD.pdf↑

• [183] More detail is provided as follows. In Norfolk see www.norfolk.gov.uk/what-we-do-and-how-we-work/policy-performance-and-partnerships/policies-and-strategies/roads-and-travel-policies/transport-asset-management-plan in particular map ciii of the appendices. In Suffolk Part 1 of the Suffolk Local Transport Plan has a principal routes diagram on page 35: www.suffolk.gov.uk/roads-and-transport/transport-planning/transport-planning-strategy-and-plans/ and there is also the Suffolk County Council’s Recommended Lorry Route Network Map (www.suffolk.gov.uk) ↑

• [184] Strategic road network and the delivery of sustainable development - GOV.UK (www.gov.uk) ↑

• [185] Management Plan 2019 - 2024 - Norfolk Coast Partnership (norfolkcoastaonb.org.uk) ↑

• [186] The star rating protocol, set out by the International Road Assessment Programme (iRAP), is a way to measure how safe our roads are. Every five years, our road network is surveyed and independently assessed to calculate star ratings. iRAP Star Ratings are used for road safety inspection, road safety impact assessments, and in designs. Star Ratings are an objective measure of the level of safety which is 'built-in' to the road through more than 50 road attributes that influence risk for vehicle occupants, motorcyclists, bicyclists, and pedestrians. 1- star is the least safe and 5-star is the safest. ↑

• [187] A47 Wider Economic Benefits Why does the A47 need dualling? (a47alliance.co.uk) ↑

• [188] NSIP: www.legislation.gov.uk/uksi/2013/1883/pdfs/uksi_20131883_en.pdf↑

• [189] The readings taken along the Acle Straight were all over 20 arc magnitudes per second with those to the western end of the Acle Straight in particular being over 20.5 arc magnitudes per second. ↑