Part 2 : Issues and Options for the Core Strategy
VISIONS, GOALS AND OBJECTIVES
The
vision set out in the Core Strategy will be a strategic vision for the
Broads. It does not need to itemise
every issue that will be covered, but will encompass the key objectives for the
Local Development Framework (LDF). It
will be a spatial strategy incorporating the principles and proposals covered
in the various strategies and initiatives covering the Broads area, including
the Broads Plan. The vision will
underpin subsequent Local Development Documents (LDDs) that will need to be in
accordance with the vision. Underlying
the vision will be the principles of sustainable development, which are:
·
Maintain high and stable levels of economic growth
·
Social progress that recognises the needs of everyone
·
Effective protection of the environment; and
·
Prudent use of natural resources
The
draft RSS sets out the following vision for the Broads area:
“The Norfolk and Suffolk Broads will be
maintained as a unique and special landscape and wildlife resource with its own
sense of place. A planning policy
framework for economically and environmentally sensitive development will
underpin a thriving community. The
framework will support innovation and diversification, and promote sustainable
transport infrastructures. Development
on the flood plain will be limited to that which is essential for the social
and economic well-being of the area and appropriate with respect to the
character of the landscape and risks from flooding”.
This
vision is broad, and seeks to integrate the competing demands of protecting the
special resource that the Broads represents and with meeting the social and
economic needs of both the local population and visitors to the area. It also identifies a number of the key
issues that will be developed elsewhere in the Core Strategy, including
appropriate areas for development and the risk of flooding.
The
strategic vision for Norfolk set out in the Structure Plan (1999) is to promote
sustainable development, whilst giving high priority to the protection of the wealth,
variety and distinctiveness of Norfolk’s natural and built environment
(CS1). The strategy for the Broads is
to protect and conserve the landscape, waterways and wildlife, protect and
enhance the built environment, ensure development is appropriate in scale and
location, prioritise the conservation of landscape, waterways and wildlife and
consider development proposals also having regard to the social and economic
well being of the area (ENV14).
The
overall strategic aim of the Suffolk Structure Plan (2001) is:
“to sustain and enhance the health,
quality and integrity of the built and natural environment, and to ensure that
development does not result in material damage to critical environmental
resources” (Strategic Aim 1).
The
strategy for the Broads in the Suffolk Structure Plan sets out a similar
strategy of protection and conservation to that in the Norfolk Structure Plan
(ENV21).
The
detailed policies of the Broads Local Plan (1997) have been developed in
accordance with nine guiding principles, as listed in Part 1. The overall strategy is one of protection of the
features for which the area is designated whilst allowing for essential
development to meet the social and economic needs of the communities.
Consultation on the key issues to be identified in the Core
Strategy set out the vision as set out in the RSS above. Consultees were asked whether they agreed in
principle with this vision.
Overall there was broad agreement
with the vision as set out, suggesting that the balance between the need for
protection of the landscape and wildlife and development to support the
economic and social needs of the communities has been correctly identified.
OPTION VISION 1: Should we
retain the vision as set out in the draft Regional Spatial Strategy?
A number of consultees commented
that the vision should include direct reference to navigational interests in
the Broads, reflecting the third statutory purpose of the Authority as set out
in the Norfolk and Suffolk Broads Act.
In any case, navigation interests
can be addressed on a topic-basis under the sections covering ‘Recreation and
Tourism’ and ‘Development, the Economy and Sustainable Communities’.
OPTION VISION 2: Should
the vision be amended to include reference to navigational interests?
The
Broads has suffered environmental degradation in the past, particularly in the
last 50 years, as a result of a number of pressures including agricultural
change, tourism, effluent and other pollution and lack of management. Since the establishment of the Broads
Authority, and due to considerable work and co-operation between the various
stakeholder and other bodies, both public and private, significant improvements
have been made, particularly in water quality and habitat improvement. Nonetheless, there is still the potential
for considerable improvement in the percentage of habitats identified as being
in favourable condition and the potential for enhancement is significant.
The
Authority has a statutory duty to further the conservation and enhancement of
features of interest in SSSIs and targets are set in the Public Service
Agreement (PSA) set by DEFRA.
SSSIs
in the Broads include a mosaic of lakes, fens and reedbeds, wet woodland,
grazing marsh and dykes, small areas of heathland and coastal habitats
including sand dunes. Currently 81% of
SSSIs are identified as being in ‘favourable’ condition, when measured against
PSA targets, with the target being to restore 95% to ‘favourable’ or
‘unfavourable recovering’ by 2010.
It has been suggested that the
current wording of the vision, with the reference to the maintenance of the
unique and special wildlife resource, effectively sets the current standard as
a baseline to be maintained, and that it should instead include an intention to
enhance and improve the ecological condition of the Broads and improve
bio-diversity giving greater weight to this as an objective.
The Broads area also includes a
number of Conservation Areas designated for their landscape value. The Authority will be required to undertake
an appraisal of these and identify potential enhancements; targets will then be
set. This enhancement could also be
included under the Vision.
In any case, the objective to
improve the ecological condition and landscape value can be addressed on a
topic-basis under the subsequent section covering ‘Nature Conservation’ and
‘Landscape’ respectively.
OPTION VISION 3: Should
the vision be amended to include reference to ecological and landscape
enhancement?
Around 95% of the Broads is
located within the floodplains of the Broads rivers. This fact, combined with the increasing threat from global
warming and sea level rise, means that flooding is a key issue that will have
implications across the Strategy. The
vision identifies this issue and seeks to limit development in the floodplain
to that which is essential only.
However it has been suggested that the vision should make direct
reference to means of addressing flood risk in more specific terms.
The methods suggested include the
creation of washlands, support for maintenance of the coastal defences and the
construction of the Yare Barrier. It
should be recognised that the Core Strategy will need to identify how its
objectives are to be achieved. Some of
these measures, particularly the construction of the Yare Barrier, are likely
to be beyond the capacity of the Authority to provide, although the it could
encourage and support other relevant agencies in taking this forward were it
agreed as appropriate.
In any case, the objective to
address flood risk can be addressed on a topic-basis under the subsequent
section covering ‘Flood alleviation and climate change’.
OPTION VISION 4: Should
the Core Strategy consider the identification of specific measures to secure flood
protection?
As
a low-lying wetland area sited almost wholly within the flood plains of the
rivers Yare, Bure, Ant, Thurne and Waveney over 95% of the Broads area is at
risk from flooding and the Environment Agency identifies the area as being
high-risk of flooding. Flooding can
occur as a result of high river flows or, more frequently, high sea
levels. The risk of flooding is likely
to increase with sea level rise, more intense rainfall and other changes predicted
as a consequence of climate change. The
Government’s ‘Climate Change: The UK
programme’ summarises the issue of climate change as follows:
“Climate change is one of the most
serious threats facing the world’s environment, economy and society … We have
to take practical action to deal with flooding and severe weather. But we also need to tackle climate change by
cutting the greenhouse gas emissions that cause it”.
The
Environment Agency is currently consulting on its draft Shoreline Management
Plan (SMP), which sets out its proposals for coastal defences for the
short-term (20 years), medium-term (20 – 50 years) and long-term (50 – 100
years). The EA proposes to maintain
coastal defences from Eccles to Winterton Beach Road in the medium term, which
will afford protection to the Broads at the Upper Thurne where it is
vulnerable. However, longer term
changes to this policy would have significant impacts on the Broads system.
The
impacts of flooding can be devastating both to local communities and to
wildlife and bio-diversity within the Broads, with the latter being
particularly affected by saline intrusion into the freshwater system.
Climate
change can, however, also present opportunities in the longer term for wetland
creation around the Broads and, with it, new opportunities for bio-diversity,
tourism and public enjoyment.
National
policy on flood risk is set out in Planning Policy Guidance Note 25
‘Development and Flood Risk’ (PPG25).
It advocates a precautionary and sequential approach, with the preferred
location for development being in the areas of lowest-risk of flooding and
development in the higher-risk areas only where it can be demonstrated that
there are no reasonable options available in a lower-risk category (consistent
with other sustainability objectives).
The policy does however recognise the special circumstances of areas
such as the Broads and states:
“… Where extensive areas of land fall
into the high-risk zones, further development may be needed to avoid social and
economic stagnation or blight, or to allow existing development to be
adequately protected. For example in
low-lying parts of eastern England, and in other areas there are large areas
where alternative sites in lower-risk zones are not available. Authorities in such areas should pay
particular attention to design and mitigation issues.” (para 31)
Draft
regional policy on flood risk prioritises the defence of existing properties
and the location of new development in locations with little or no risk of
flooding. It states that planning
policy will
“only propose development in
floodplains, areas at flood risk or at risk of flooding in future, or where
development would increase the risk of flooding elsewhere, where land at lower
risk of flooding is not available, where there is significant over-riding need
for the development, and the risk can be fully mitigated by design or
engineering measures.” (SS14)
The
strategic policy for flood risk set out in the Norfolk Structure Plan (1999)
states that:
“New development or the intensification
of existing development will only be acceptable in areas at risk from fluvial
flooding or in areas where it is likely to increase the risk of flooding
elsewhere to an unacceptable
level, including defined washlands,
natural flood plains, and other areas adjacent to rivers to which access is
required for maintenance purposes, where suitable mitigation measures have been
agreed” (RC3).
Similar
policies apply in the Suffolk Structure Plan (2001) stating that:
“Development will not be acceptable if
it would impede materially the flow or storage of floodwater, increase the risk
of flooding elsewhere or increase the number of people or properties at risk of
flooding” (ENV14)
and
“Development will not be acceptable
which would adversely affect the integrity of tidal or fluvial defences, or
would be likely to be affected by marine erosion during its expected lifetime”
(ENV15).
The
existing policies in the Broads Local Plan (1997) have sought to prevent
development where this would increase the flood risk, whilst the Environment
Agency has started a long-term Broads Flood Alleviation Project (BFAP)
including improved flood defences across the Broads area. When completed this will provide the Broads
with the 1995 standard of protection against flood risk.
In recognition of the significant implications of flooding for new development
in the Broads, the Broads Authority adopted Supplementary Planning Guidance
(SPG) in November 2000. This recognised
the need for some limited development in the Broads and permits this, subject
to the implementation of appropriate measures to reduce the risk of
flooding. This SPG was updated in
August 2002 to take account of the advice in PPG25, with the amendments
including the requirement for planning applications to be accompanied by a
Flood Risk Assessment.
The
Broads Plan recognises the constraints and challenges represented by the flood
plain, and Guiding Principle 13 states:
“The
flood plain will be managed sustainably to alleviate flooding in the Broads,
taking into account the impacts of climate change and rising sea levels. Cost-effective benefits to enhance the
landscape, bio-diversity, recreation and navigation will be sought in conjunction
with flood alleviation works. Development
on the flood plain will only be allowed if it is essential for the social and
economic well-being of the community and appropriate to the character of the
landscape and risks from flooding”.
Climate change
There is overwhelming evidence that the rate of climate change is increasing more rapidly than previously experienced in the Earth’s history. Changes in the UK over the next 100 years are predicted to include 2 –5 degree c rise in temperature, 26 – 28 cm rise in the sea level at Great Yarmouth and wetter winters and drier summers. The impacts on the Broads are likely to include greater demand for water resources, increased flood risk, intrusion of saline water into freshwater systems, changes in habitat and species distribution and a more productive wetland system requiring greater management.
(The Broads Plan 2004)
Consultation
on the key issues to be addressed in the Core Strategy suggested the following
issues which were raised in the preparation of the Broads Plan:
·
Addressing and planning for the impacts of sea level rise
and climate change
·
Flood defence and the impacts of and opportunities under the
Broads Flood Alleviation Project (BFAP)
·
Development within the flood plan
Consultees
were asked for their views on these issues and whether there were further
factors that the Authority should be looking at.
Overall, consultees agreed that
these were the main issues that the Core Strategy should be addressing, with
flood alleviation identified as the main priority. There is a range of solutions that could be adopted to address
the issue of flood alleviation – from the low-tech managed re-alignment to the
extensive engineering works that would be involved in the construction of a
tidal barrier – and many ideas were put forward as part of the
consultation. Each solution would
potentially have a different outcome in terms of level of protection provided,
longevity of solution and cost; and some would meet sustainability objectives
better than others. The impact of any
scheme on the special landscape and wildlife value of the Broads, as well as
the navigation interests, would also have to be taken into account.
This issue also arose in response
to the draft vision, with suggestions that specific measures to provide flood
alleviation be included in the vision.
The vision and the strategic policy for flood alleviation will need to
be consistent with each other.
OPTION
F&CC 1: Should the Core Strategy
examine the options for flood alleviation?
The BFAP project is a 20-year scheme run in partnership
between the Environment Agency and its private sector partners Broadland
Environmental Services Ltd (BESL) which seeks to provide flood defence to 1995
levels. This is achieved primarily
through engineering means by increasing the height of floodbanks and/or setting
them back to increase the area of rond available to absorb flood water. One of the Guiding Principles of the Broads
Plan is to increase the capacity of the flood plain to function more naturally
and the maintenance of an engineered solution may not be the most sustainable
or appropriate approach in the long-term.
Historically,
development has been permitted on the flood plain because there is very little
non-flood plain land within the Broads Authority area. This development is often related to the
tourism and recreation industries and helps to support the local communities
both socially and economically. Design
is always a prime consideration in such areas, not simply for aesthetic reasons
within this protected landscape but to ensure that the development would not
increase flood risk and would be able to withstand a degree of flooding. The current Broads Flood Alleviation Project
will provide protection to 1995 levels, but future mitigation measures and
technological innovation may improve on this.
Holiday
accommodation has been permitted in areas where permanent residential
properties would not be permitted, due to the differing patterns of occupation
and expectation. Other development may
relate to boating or water-based industries where a riverside location is
essential. In practical terms, the
level of acceptable flood risk may vary, depending on the type of development
and extent of the risk and the current policies have sought to reflect this.
With
increased risk of flooding in the long term, however, it is timely to
reconsider what development is appropriate in the flood plain, particularly
given increased pressures for development.
Weight must also be given to future risk, notwithstanding the scientific
uncertainties regarding its extent.
There are other factors which will increase risk, including development
elsewhere (i.e. beyond the Broads area) which can result in loss of flood
storage capacity and fluvial flooding.
Risks relate not just to property, but also to essential infrastructure
and utilities required to facilitate and support development, and flooding can
cause severe disruption and pollution.
Consultees raised the issue of how ‘essential development’ would be
defined.
Sustainable Drainage Systems
(SUDS)
Flooding and pollution risk is increased by development
which reduces surface permeability and consequently increases the rate of
surface run-off. In the event of flood
or high rainfall, the increased and uncontrolled surface run-off can cause
problems of erosion, flooding down-stream or the movement of pollutants. An important ‘soft’ engineering approach to
flooding and pollution prevention is to incorporate Sustainable Drainage Systems
(SUDS) in the design for new development.
These mimic a more natural drainage system and use techniques to control
surface water run-off as close to its origin as possible, before it enters a
watercourse. Government advice
recognises SUDS as being one of the most effective ways to reduce pollution and
flooding risk.
Development
in the floodplain is also relevant with regard to Guiding Principle 13 in the
Broads Plan which seeks to improve the sustainability of the management of the
flood plain, and inappropriate development could compromise this.
The
draft vision above seeks to limit development in the floodplain to that which
is essential. Both the vision and the
strategic policy for flood alleviation will need to be consistent with each
other.
The need to limit or prevent
development in the flood plain in order to minimise risk to property and allow
the proper functioning of the flood plain was raised extensively as part of the
consultation. There are a number of
options to address this issue and each has its own implications.
OPTION
F&CC 2: Should the Core Strategy
prevent all future development in flood plain and high risk areas?
OPTION
F&CC 3: Should the Core Strategy
limit development in the flood plain and high risk areas to that which is
essential, with criteria listed against which ‘essential’ can be measured?
OPTION
F&CC 4: Should the Core Strategy
identify essential development which will be permitted within the flood plain
and high risk areas? This could include
tourism and recreation businesses which require a waterside location.
OPTION
F&CC5: Should the Core Strategy identify sequential zones, including the
identification of areas which are likely to become at a greater risk and seek
to locate development only within lower risk areas unless there are specific
factors which require a waterside location?
A
number of comments were made on the opportunities represented by the BFAP to
increase bio-diversity and/or the provision of moorings and these will be
addressed under the relevant section in this Report.
Finally,
it was observed that flooding issues are not just restricted to the Broads and
will affect communities beyond the Broads.
These communities will be affected by the policies in the Core Strategy. The need to work with closely adjacent
authorities was noted.
The
Broads is designated National Park stat us in recognition of the national
importance of the area for its landscape value. There is a short coastal strip which overlaps with part of the
North Norfolk Coast Area of Outstanding Natural Beauty (AONB) and in this area
the AONB Management Plan is a consideration.
‘Landscape’
as a term is multi-faceted and covers more than just the view that we see. It also includes components such as visual
amenity, character, integrity and sensory factors, which are harder to identify
and quantify than a view, and consequently more sensitive and vulnerable to
change.
In
recognition of the national importance of the landscape, national policy in
Planning Policy Statement 7 ‘Sustainable Development in Rural Areas’ (PPS7)
affords the Broads and the AONB the highest level of protection from
inappropriate development, setting out the level of protection thus:
“…The
conservation of the natural beauty of the landscape and countryside should
therefore be given great weight in planning policies and development control
decisions in these areas. The conservation of wildlife and the cultural
heritage are important considerations in all these areas. They are a specific
purpose
for National Parks, where they should also be given great weight in planning
policies
and development control decisions … Major
developments
should not take place in these designated areas, except in exceptional
circumstances …” ( para 21).
Regional
policy reinforces this approach, stating:
“Planning authorities and other
agencies in their plans, policies and programmes will provide the strongest
levels of landscape character protection for the East of England’s finest
landscapes and areas of national importance
- the Broads … The diversity and
local distinctiveness of landscape character throughout the East of England
should be protected and enhanced …” (ENV 2).
Regional
policy goes on to require that planning authorities use their plans, including
the LDF, as a means of conserving and enhancing landscape character.
The
strength of national and regional policy means that protection of the landscape
of the Broads is of paramount importance, and this is welcomed and supported by
the Broads Authority.
The
strategic landscape protection policy for Norfolk set out in the Structure Plan
(1999) states:
“Development which would be detrimental
to the character of Areas of Outstanding Natural Beauty, the Heritage Coast and
the Broads will not be permitted unless there is an overriding proven national
need for the development and there are no suitable alternative sites” (ENV2).
Similar
policies apply in the Suffolk Structure Plan (2001) and state:
“Development which would have a
material adverse impact on the Broads, Areas of Outstanding Natural Beauty, or
the Heritage Coast will only be acceptable where an overriding national need
for development in the particular location can be demonstrated and there is a
lack of acceptable alternative sites. Where development proceeds because of an
overriding national requirement, removal and restoration of the site will be
required in the event of redundancy at a later date” (ENV7).
The
current policies in the Broads Local Plan (1997) are restrictive and
specifically protect the various landscape types within the Broads.
The
principle of protection of the special character of the area is carried forward
into the Broads Plan, where Guiding Principle 2 states:
“The
tranquillity and wildness of the Broads will be protected and enhanced for
people to enjoy”.
It
is recognised, however, that a living landscape will change and evolve in
response to both internal and external pressures. The challenge is to accommodate necessary change in a way that
will not damage the special characteristics of the area. Furthermore, change can be positive and
offer opportunities for enhancement.
Guiding
Principle 6 of the Broads Plan recognises these challenges, stating:
“The Broads’ landscape is unique and
reflects the interaction of people with nature over time …. Its physical,
natural and cultural distinctiveness will be restored, maintained, enhanced and
protected from intensive or inappropriate land use and development, while also
allowing for its continuing evolution within levels that can be sustained by
the environment …”
Consultation
on the key issues to be addressed in the Core Strategy suggested the following
issues which were raised in the preparation of the Broads Plan:
·
Protecting the value of the landscape as a whole
·
Preserving local distinctiveness and character
·
Protecting tranquillity
·
Protecting the landscape whilst allowing essential
development
Consultees
were asked for their views on these issues and whether there were further
factors that the Authority should be looking at.
Overall, consultees agreed that
these were the main issues that the Core Strategy should be addressing, with
the need to maintain tranquillity and protect large scale landscape value and
local distinctiveness identified as priorities.
OPTION
LWL1: Should the Core Strategy protect
landscape value as an over-riding priority?
Despite
its local distinctiveness, the landscape of the Broads is not homogenous. There is a marked difference, for example,
between the enclosed, intimate character of some parts of the Upper Thurne, and
the wide open spaces of Halvergate Marshes.
Therefore while the need to protect the landscape is agreed as a
priority, and is supported by national and regional and local policy and the
Broads Plan, there may be areas that are better able to accommodate growth
and/or change than others. The
Authority is currently studying the variety of landscapes across the area
through a Landscape Character Assessment.
This work will help to inform the development of landscape policy by
identifying which areas are more and less vulnerable to change. It will also provide detailed advice on
landscape matters. Any location
identified for development would also need to be assessed against
sustainability criteria.
Landscape
Character Assessment
The Landscape Character Assessment (LCA) will combine
desk-based analysis and extensive field survey work looking at a wide range of
factors influencing the character of the Broads landscape. The process will identify what makes one
area different from another and identify distinct local areas. The process will also identify the key
characteristics that combine to give a particular area its unique sense of
place.
The work will include collaboration with a number of
community organisations. The draft
assessment will also be made available for wider consultation. The main assessment is currently underway
and is programmed for completion at the end of March 2006.
The work will be used to inform decision-making and in
developing strategies and guidance for the conservation and management of the
distinctive landscape of the Broads, which is a 5 year priority objective in
the Broads Plan.
Similarly, comments were received
regarding the protection of ‘tranquillity’.
It was noted that this is not always achievable or desirable and that
the Broads should offer a range of experiences, including the more social and
bustling boating environments found, for example, in Great Yarmouth and
Wroxham. The classification of the
different landscape types within the Broads would help to differentiate between
the various areas and ensure that policies offer a level of protection that is
appropriate.
Whilst protection is recognised
as important, some respondents referred to the need to balance protection with
the needs of a ‘living landscape’, which will involve permitting development
necessary to support local communities and the economy. This will not necessarily involve landscape
harm, subject to careful siting and design.
OPTION
LWL2: Should the Core Strategy set
over-riding strategic criteria against which landscape impact can be assessed,
within a general framework of protection and restraint?
OPTION
LWL3: Should the Core Strategy identify
areas where development would be appropriate in landscape terms, within a
general framework of protection and restraint?
While the Broads landscape as a
whole is protected for its natural beauty and national significance, there are
areas that have suffered from inappropriate development or neglect. A number of consultees commented that
preservation alone was insufficient and that policies should include
enhancement. This could include
enhancement to the quality of built development, including, where possible,
removing obtrusive and inappropriate development, and landscape
enhancement. An example given of this
was the removal of trees along the water’s edge to open up wider views where
appropriate and improve conditions for safety.
Landscape enhancement can also offer bio-diversity gains and
opportunities to improve facilities for navigation and recreation.
It should be recognised that such
enhancements will involve change and there will be differing views on the
appropriateness of change. The
potential changes could be small-scale or strategic.
Consultees pointed out that
agricultural change may offer opportunities to enhance the landscape.
OPTION
LWL4: Should the Core Strategy require
enhancements to the landscape? If so,
where?
The Environmental Stewardship Scheme (ESS) is one of the new
schemes available to farmers and landowners under the changes to the way in
which agricultural support is delivered.
It is intended to build on the recognised successes of the
Environmentally Sensitive Areas scheme (ESA), pioneered originally on
Halvergate Marshes, and the Countryside Stewardship Scheme. Its primary objectives are to conserve
wildlife (bio-diversity), maintain and enhance landscape quality and character,
protect the historic environment and natural resources and promote public
access and understanding of the countryside.
Its secondary objectives cover genetic conservation and flood
management.
Further details can be found at www.defra.gov.uk
The extent and complexity and
cost of landscape enhancement are likely to vary across the area and according
to scale of project , nonetheless there will be a financial commitment
required. Whilst the Authority will fund
its own landscape development projects these resources are limited and will not
meet the cost of all the works which are necessary.
There is a high demand for
development, particularly housing, both in and adjacent to the Broads and this
is in part due to the quality of the environment and the opportunities for
recreation offered. Given that the
value of the natural resource contributes to the demand for the development it
may be appropriate to seek contributions from developers towards the costs of
landscape restoration and enhancement, which would include works to the
cultural landscape.
Were such an approach to be
adopted it would involve the need to work closely with adjacent authorities,
other organisations and landowners.
OPTION
LWL5: Should the Core Strategy seek
contributions from developers towards landscape restoration and enhancement on
the basis that the quality of the natural resource contributes to the demand
for the development?
The
impact of development beyond the Broads Authority boundary was an issue that
was raised under the sections on ‘Nature Conservation' and ‘Housing’,
particularly the impact that this could have on the Broads area. The Broads landscape is not just at risk
from development within the Broads area – development in adjoining Districts
can potentially have a significant effect and this is compounded by the
tightness with which the boundaries are drawn.
The Authority and consultees and other stakeholders can seek to
influence adjacent Councils to ensure that policies are in place which cover
development which would have a significant impact on the Broads, however their
inclusion in the LDF and subsequent interpretation is a matter for the
Districts. In response to this, and to
increase the influence of the Authority, the consideration could be given to
the designation of a Zone of Visual Influence to protect the Broads from any
potential adverse impacts of development in adjacent Districts.
In order to progress such an
approach it would be necessary to work in close co-operation with the adjoining
Districts.
OPTION
LWL6: Should the Core Strategy seek to
identify a Zone of Visual Influence between the Broads and the surrounding
landscape where specific criteria would apply in relation to development?
The
LDF should not only cover landscape issues, but should include social and
community requirements too, which would include the needs of the local
economy. This will involve the need to
work closely with adjacent authorities and stakeholders.
The
built and historic environment is an important part of the cultural landscape
and reflects the activities of people living and working in the Broads over
time. There are 18 Conservation Areas
covering both the built and the natural environment, with Halvergate Marshes
being the largest, and nearly 250 listed buildings. There are over 70 surviving drainage mills, 13 Scheduled Ancient
Monuments and over 1000 records on the Site and Monuments Register. Together these contribute significantly to
the character and distinctiveness of the Broads.
National
policy on the historic environment is set out in Planning Policy Guidance Note
15 ‘Planning and the Historic Environment’ (PPG15). The overall policy is protective and states:
“It
is fundamental to the Government’s policies for environmental stewardship that
there should be effective protection for all aspects of the historic
environment. The physical survivals of
our past are to be valued and protected for their own sake, as a central part
of our cultural heritage and our sense of national identity … Their presence
adds to the quality of our lives, by enhancing the familiar and cherished local
scene and sustaining the sense of local distinctiveness which is so
important
an aspect of the character and appearance of our towns, villages and
countryside.” (para 1.1).
At
a regional level policies require that planning authorities use their plans,
policies and proposals to:
“… identify,
protect, conserve and, where appropriate, enhance the historic environment of
the region, its archaeology, historic buildings and areas and historic
landscapes, including those features and sites (and their settings) especially
significant in the East of England …” (ENV5).
The
particular features and sites of importance to the Broads include listed
buildings and conservation areas – both domestic and industrial and the
settlements and settings which define their character – and the wider historic
landscape. This will include
distinctive but unlisted features.
The
Norfolk Structure Plan (1999) seeks to maintain and improve the quality and
distinctiveness of the historic built environment by ensuring adequate
protection is in place for all important buildings, structures and features,
encouraging appropriate re-use which is not detrimental to the integrity of any
such building, requiring recording of features that cannot be preserved and
resisting inappropriate development within Conservation Areas (ENV13).
It
recognises that the historic landscape and the form and character of
settlements are strongly related, both having developed over many centuries in
response to changing patterns of land use and reiterates the importance of
their protection.
A
similar degree of protection is applied in the Suffolk Structure Plan which
protects Conservation Areas and listed buildings from inappropriate development
(ENV1) whilst the importance of the importance of the environment as a whole is
reflected throughout the Plan.
The
specific policy on re-use of buildings states:
“The conversion or re-use of sound,
traditional rural buildings will be supported where consistent with other
Structure Plan policies, particularly where employment can be generated and
where a significant environmental benefit would result from their retention.
The conversion or re-use of other sound rural buildings for employment or
tourism purposes will be acceptable where the building and the proposed new use
respect the rural setting. Proposals likely to lead to unacceptable levels or
types of traffic or problems of road safety will not be acceptable” (ENV2).
The
principles of the Broads Local Plan (1997) seek to control and influence the
effect of new development on the buildings and settlements of the Broads and
will have particular regard to Conservation Areas and listed buildings. The aim is to ensure that the special
character of the Broads built environment is protected and enhanced and that
where new development is appropriate its design is of a high quality and
enhances the character of the Broads.
Whilst this objective refers specifically to the built environment, the
approach is also relevant and applicable to the wider historic and cultural
environment, in that protection and enhancement are sought by the policies in
the Plan as a whole.
The
importance of the interconnections between the historic and natural landscape
and the communities that have shaped them is recognised in the Broads Plan,
where Guiding Principle 6 states:
“The
Broads’ landscape is unique and reflects the interaction of people with nature
over time. Its archaeological features
will be identified, evaluated and appropriately safeguarded prior to any
development, including provisions for flood alleviation. Its physical, natural and cultural distinctiveness
will be restored, maintained, enhanced and protected from intensive or
inappropriate land use and development, whilst also allowing for its continuing
evolution within levels that can be sustained by the environment”.
Consultation
on the key issues to be addressed in the Core Strategy suggested the following
issues which were raised in the preparation of the Broads Plan:
·
Protecting and enhancing the historic and cultural landscape
·
Preserving key landmark buildings and heritage features
·
Developing new uses for cherished buildings
Consultees
were asked for their views on these issues and whether there were further
factors that the Authority should be looking at.
Consultees supported the
objectives of the Core Strategy as being the protection and enhancement of the
historic and cultural landscape, the preservation of key landmark buildings and
features and the development of new uses for cherished buildings.
The
protection of the cultural landscape is part of the new first purposes of the
Broads, which is to be introduced under the Natural Environment and Rural
Communities Bill. Whilst the cultural
landscape has received a degree of protection under development plan policies,
its inclusion in the statutory purposes will strength that protection.
In
developing LDF policy for the protection and enhancement of the historic and
cultural landscapes, it is important to distinguish between the two as, whilst
related, they are not interchangeable which has implications for their
protection.
The historic landscape
will include buildings and their landscape context in a primarily physical
form; cultural landscape relates more to the inter-relationships between
landscape and buildings and the way in which they both developed and are now
experienced. The cultural landscape is
therefore broader and may be vulnerable to change in a different way to the
historic landscape, both from the loss of old features or uses and the
introduction of new ones. The cultural
landscape also includes new buildings and structures.
The
Broads Authority is currently developing a Cultural Heritage Strategy, part of
which will include a review of all the existing designations, starting with the
statutory designations. There are 18
Conservation Areas within the Broads and a review of these is proposed from
2006. As a result of the review the
Authority may need to reconsider some of the existing boundaries and extend or
reduce the land included within the Conservation Area; similarly there may be a
need to designate new areas. To an
extent, any changes deemed necessary to the Conservation Areas will give an
indication of the success, or otherwise, of Conservation Area protection
policies. The need for strong Conservation Area protection policies is recognised
and this is included within the issue of general protection. As part of the Cultural Heritage Strategy
the Authority will also be identifying undesignated sites and landscapes of
historic and cultural interest.
The
Government is currently consulting on changes to the criteria for listing as
part of their heritage protection review.
If agreed, English Heritage will take over the listing process and will
undertake a full review of listed buildings.
The Authority is committed to the development of a Cultural
Heritage Strategy (CHS). Survey-based,
the purpose is to quantify the quality, condition and relative importance of
all aspects of the cultural heritage, including structures and features. It will then identify and cost the necessary
works for the improvement of the asset and this will guide the future
management and use of the asset.
A pilot study has been completed and will be rolled out over
the whole area in due course. The CHS
process will involve consultation to understand the aspects of the cultural
landscape that are important to communities and stakeholders.
The conclusions will be used to inform the local list of
important buildings and Conservation Area Appraisals. The CHS links to the 20-year aim in the Broads Plan to understand
the character of the Broads as a living, working landscape.
OPTION
HCE1: Should the Core Strategy protect
and enhance the historic and cultural landscape as a key priority?
Support from consultees for the
enhancement of the historic and cultural landscape, rather than simply
protection, reflects pressures on the Broads, particularly in recent years, and
concerns about incremental degradation through specific actions or simple
neglect.
Where ‘enhancement’ is included
in the Vision for the Core Strategy, the enhancement referred to here might
identify how the policies would seek to implement this.
A number of consultees suggested
that enhancement of the historic and cultural landscape would be achieved by
the re-opening of formerly navigable waterways to increase the area available
for recreation. The Authority could
consider this and other enhancements and specify those that are being
sought. Were the Authority to adopt the
latter approach it may be necessary to identify the mechanism by which such
re-development would be achieved. This
might be achieved through the Conservation Area Appraisals which could offer
encouragement and advice regarding the re-use of redundant buildings.
OPTION HCE2: Should
the Core Strategy define ‘enhancement’ and specify the measures to be taken?
The Broads landscape, both
natural and built, includes many buildings and structures which will never be
listed, but are characteristic of the area and contribute to the special and
distinctive cultural environment.
Although given general protection within the context of ‘cultural
landscape’ they have no statutory designation and are vulnerable to
change. A number of consultees
suggested that a survey of buildings be undertaken to identify the key structures
and this is a project to which the Authority is already committed under the
Cultural Heritage Strategy. Having
identified them, it may be appropriate to introduce a further local designation
in order to ensure their protection.
OPTION HCE3: Should
the Core Strategy establish a local designation to protect buildings of local
interest or which are typical or distinctive within the Broads, but not subject
to statutory designation?
Flood risk and
design
Most of the
area covered by the Authority is within the flood plain and planning
applications will require a Flood Risk Assessment under Planning Policy
Guidance Note 25 (PPG25). PPG25 is to
be replaced by new guidance in Planning Policy Statement 25 (PPS 25) which will
further strengthen the requirement for flood risk assessment.
In order to
address flood risk for a building which is proposed for habitation, rather
than, for example, a boat shed, the floor level will need to be raised to a
given level stipulated by the Environment Agency as being appropriate to
minimise flooding. This will inevitably
influence the design of the building, which will need to be raised, and has
implications in an area where the traditional form has been one of relatively
low buildings. A secondary impact
arises from the trend for upper floors, which again are not traditional, and
the inevitable increase in height that this will involve will also impact on
the area.
Policies for
replacement dwellings and holiday accommodation will need to acknowledge and
address these issues and the design advice provided by the Authority will need
to be updated to reflect this and offer guidance on mitigation. The Authority will prepare a Supplementary
Planning Document (SPD) to cover this.
As with
landscape policies, ’protect and enhance’ cannot be solely about preventing
change and development, but includes ensuring that such change is permitted
where appropriate given the special characteristics of the area. There are many pressures for the re-use of
buildings within the Broads – typically for residential or holiday
accommodation – and conversion in some circumstances may be appropriate.
Amongst consultees there was support in principle for new uses for historic
buildings and structures, subject to this not being to the detriment of the
distinctive character or wildlife interest, and a number of uses were
suggested. In taking this forward the
Authority could either set criteria against which proposals for re-uses could
be judged or identify appropriate uses for particular buildings, or groups of
buildings. Were the Authority to adopt
the latter approach it may be necessary to identify the mechanism by which such
re-development would be achieved.
It was pointed
out that re-development for its own sake can be inappropriate and where repair
would threaten the integrity of a building, perhaps where the extent of works
is substantial, it may be preferable to allow buildings to decline gracefully
as ‘romantic ruins’. A degree of
dereliction hints at an historic past and prevents the Broads becoming
‘themed’, which is a concern raised by many consultees.
OPTION
HCE4: Should the Core Strategy set
criteria against which re-use of historic buildings can be assessed, within a
general framework of protection?
OPTION
HCE5: Should the Core Strategy identify
appropriate uses for historic buildings, within a general framework of
protection.
The Broads is designated
National Park status in recognition of the national importance of the area for
its nature conservation value, being the largest and most important wetland in
the UK.
There are 28 Sites of
Special Scientific Interest (SSSIs) which cover about 24% of the Broads
Authority Executive area and of which one-third are designated National Nature
Reserves (NNR). Virtually the entire
SSSI network is designated as internationally important for nature conservation
and has either Special Protection Area or candidate Special Area of
Conservation (cSAC) status under European legislation; a large number of SPAs
are also Ramsar sites.
The natural resource as a
topic covers a range of issues and factors wider than just areas of protected
habitat and nature conservation. It
might include water, air, tranquillity, and darkness, as well as bio-diversity,
which is a component of protected habitat but also a resource in its own
right. It might also include factors
such as renewable energy and resource conservation although these have not been
directly raised in the consultation on issues to be addressed.
There are clearly linkages
to other aspects of policy, with, for example, the issue of light pollution
being relevant to the landscape protection policies.
Policy context
National policy on nature
conservation is set out in Planning Policy Guidance Note 9 ‘Nature Conservation
(PPG9). It emphasises protection,
whilst allowing for exceptional development subject to minimisation of damage,
and states:
“…The Government’s objectives for
nature conservation are to ensure that its policies contribute to the
conservation of the abundance and diversity of British wildlife and its
habitats, or minimise the adverse
effects on wildlife where conflict of
interest is unavoidable, and to meet its international responsibilities and
obligations for nature conservation” (para 2).
Draft regional policy
reiterates the need for the strongest level of protection to apply to
nationally- and internationally-designated sites, but also sets out the need
for positive change too in stating:
“… The region’s bio-diversity, earth
heritage and natural resources will be protected and enriched through
conservation, restoration and re-establishment of key resources by:
·
promoting the restoration and re-establishment of habitats
and species populations in accordance with
… biodiversity targets
·
identifying and safeguarding areas for habitat restoration
and re-establishment, in particular for large scale (greater than 200ha)
habitat restoration which bring associated social and economic benefits
·
ensuring that all new development minimises any damage to
biodiversity and earth heritage resource and, where possible, enhances it
….” (ENV3)
The
Norfolk Structure Plan (1997) sets a hierarchy of protection, with the highest
level of protection granted to internationally designated sites such as Ramsar
sites, SPAs and SACs where no development will be permitted which would
adversely affect, whether directly or indirectly, the integrity of such sites
unless there is there is no alternative solution and there are imperative
reasons of overriding public interest and appropriate compensatory measures can
be agreed (ENV6). On nationally
designated sites, a high level of protection is afforded and development will
only be permitted where planning conditions or obligations will prevent any
damaging impact on the site or there are other imperative factors which
override the nature conservation importance of the site (ENV7). On sites of local importance development
will only be acceptable where it can be demonstrated that there are reasons for
the proposals which outweigh the need to safeguard the nature conservation
interest of the site (ENV8). All areas
of wildlife value, whether designated or not, receive a degree of protection
under the Norfolk Structure Plan policies (ENV9).
The
Suffolk Structure Plan (2001) similarly applies a hierarchy of protection,
although the highest level of protection applies to both internationally and
nationally designated sites, which receive a similar level of protection to
that set out in the Norfolk Structure Plan policy ENV6 (ENV18).
Regionally and locally designated sites receive a high level of
protection which states:
“Development will not be acceptable
which would have a material adverse impact on regionally important habitats, in
particular County Wildlife Sites, regionally important geological or
geomorphological sites, or sites proposed for such designations. The only exception to this policy will be
where an overriding national or local need for development in the particular
location can be demonstrated and there is a lack of acceptable alternative
sites. Significant habitat creation measures and/or improved management
measures for existing habitats will be required” (ENV19)
and
this emphasis on habitat creation and management is in accordance with current
national policy.
There
is also a specific policy on the need to preserve and enhance bio-diversity
(ENV20).
The national requirement
for positive change and improvement to nature conservation value set out in
national and regional policy is a change from the existing Broads Local Plan
(1997) policies, which are simply protective, however it does accord with the
objectives of the Broads Plan, particularly Guiding Principle 5 which states:
“…Habitats,
with their associated plants and animals, will be maintained and enhanced to
protect them from damaging development, and degraded habitats will be restored
to good ecological status.
Opportunities will be sought to create new habitats to counter historic
trends in the fragmentation and degradation of habitats, and to increase the
capacity of the flood plain to function more naturally”.
Consultation
on the key issues to be addressed in the Core Strategy suggested the following
issues which were raised in the preparation of the Broads Plan:
·
Habitat protection, restoration and recreation
·
Impact of nature designations and international obligations
·
Promoting wildlife gain through management
·
Improving bio-diversity
Consultees were asked for their views
on these issues and whether there were further factors that the Authority
should be looking at.
Consultees broadly supported the
objectives for nature conservation raised in the Broads Plan, although a number
of consultees referred to the balance in the Broads Act between the three equal
purposes of protection, recreation and navigation and reiterated the principle
that none had precedence. This latter
issue was raised in respect of the vision which may be the appropriate place to
address this. Considerable emphasis was
placed on habitat enhancement, recreation and bio-diversity improvements in the
specific comments received.
The objectives outlined from the Broads
Plan reflect a change in emphasis from protection alone to enhancement and
habitat recreation which is supported by national and regional policy. It reflects sustainability principles and is
partly a response to previous patterns of environmental degradation and habitat
loss and is informed by increasing knowledge of the functioning of eco-systems. The promotion of habitat recreation would
also help to re-establish vulnerable species and habitats to more viable
population levels and enable them to adapt better to change in the medium and
longer-terms.
This raises the issue of where the
balance should lie between the need to protect or conserve and the requirement
to enhance and improve, as habitat enhancement may not be appropriate in all
places and for all species or habitat types.
There is also a distinction between habitats which are valuable in their
own right and those which have perhaps a more ‘social’ value and contribute to
the landscape and/or economic value of the Broads.
Unlike the balance between protection
and enhancement which could apply for landscape and historic and cultural
landscape policies, the nature conservation resource may be more easily
quantified and specific pro-active objectives for enhancements set, taking into
account national bio-diversity targets and those set in the Norfolk
Bio-Diversity Action Plan (BAP), which identify priority species and habitat types. Not all of the habitats in the BAP are
appropriate to the Broads and it might be useful to identify these.
The Authority also has in place a number of strategies to
restore the quality of other habitats within the Broads, including the Fen
Management Strategy and the Carr Woodland Strategy.
Further details can be found at www.broads-authority.gov.uk
by following the links to ‘Conservation’.
OPTION
NR1: Should protection, enhancement and
habitat recreation be a key objective across the area?
OPTION
NR2: Should the Core Strategy set
criteria against which the need for enhancement and habitat recreation will be
required, within a general framework of protection?
OPTION
NR3: Should the Core Strategy identify
areas or habitat types where enhancement and recreation will be required,
within a general framework of protection?
The extent and complexity and
cost of habitat enhancement are likely to vary across the area and according to
scale of project, nonetheless there will be a financial commitment
required. Whilst the Authority will fund
its own landscape development projects these resources are limited and will not
meet the cost of all the works which are necessary.
There is a high demand for
development, particularly housing, both in and adjacent to the Broads and this
is in part due to the quality of the environment and the opportunities for
recreation offered. Such development
will, however, place additional pressures on the local environment and habitats
and it may be appropriate to seek contributions from developers towards the
costs of protecting and maintaining the quality of the natural resource which
contributes to the demand.
Were such an approach to be
adopted it would involve the need to work closely with adjacent authorities.
OPTION NR4: Should
the Core Strategy seek contributions from developers towards the cost of
protecting and maintaining the quality of the natural resource?
In addition to the provision of
habitats, consultees expressed support for policies to encourage the
improvement of management for wildlife, both to promote gain through, for
example, promoting wildlife corridors to link fragmented habitats, and support
the existing ecosystems.
OPTION NR5: Should
the Core Strategy identify new areas to link existing fragmented habitats?
Green
Initiatives and the Green Grid
In the Thames Gateway area the ODPM is promoting an
initiative called ‘Greening the Gateway’ which will help to deliver sustainable
communities. It encompasses a wide
range of practical greening initiatives with the common theme of taking an
holistic approach to the green environment and strengthening the overall
integrity of the landscape by forging a more complete network of linked sites
and by emphasising the strength and diversity of the existing natural and
cultural heritage of the region. It is
a collaborative approach to existing and potential green space and has been
developed by partnerships of local authorities and others. The precise approach varies from place to
place, but in each case Green Grid emphasises the importance of physically
linking together parcels of green space.
In addition, Green Grid pays particular attention to the practical
environmental, economic and social benefits which both urban and rural
greenspace can deliver, and it serves to champion the need for increased
landscape integrity to all its supporting partners.
Whilst the Green Grid focuses on the provision of
green space and seeks to integrate this into regeneration plans and proposals
for the area, the principles could be applied to the natural resource as a
mechanism for linking habitats in an holistic way.
Further details can be found at www.odpm.gov.uk
by following the links to ‘Sustainable Communities.
As a wetland system the Broads is
highly managed, including the control of water levels and the management of
vegetation and species. At Barton Broad
bio-manipulation has resulted in an improvement in water quality leading to the
re-establishment of a healthy aquatic community and management elsewhere
results in benefits to both landscape and nature conservation value. In the long-term and across the system as a
whole, however, intensive management is unsustainable and resource-heavy and
the Broads Plan objective is to move towards a more naturally functioning system. This will involve change and this must be
prepared for.
Over the timescale of the LDF
there will be opportunities to reduce management and move towards a more
self-sustaining flood plain environment and consultation responses indicate
that these should be included in the Core Strategy policies to link in with and
take advantage of complementary strategies.
Examples of this include
opportunities under BFAP to explore the creation of washlands to take excess
flood water and fluvial retreat; these could also have benefits in terms of
landscape, bio-diversity the provision of recreational space as well as having
implications for flood alleviation.
This issue was also raised in the section on ‘Flood Alleviation’ and
could link in with work being done under BFAP.
OPTION NR6: Should
the Core Strategy examine and identify opportunities for sustainable flood
plain management which will offer nature conservation benefits and other gains?
Consultees
raised the issue of water quality, recognising that one of the greatest threats
to the Broads environment is pollution, particularly water pollution. In the past, phosphate discharge from sewage
treatment works was a significant problem, leading to eutrophication of the rivers
and Broads, but considerable progress has been made in reducing this and the
benefits are apparent. Current
pollution threats arise from direct pollution from, for example, boating
activities, and diffuse pollution from, for example, agricultural run-off and
development beyond the boundaries of the Authority area. The potential points of discharge are
multiple and dispersed across the Authority area, which makes addressing the
issue challenging.
The Water Framework Directive
The Water Framework Directive is a catchment-based approach
to water resource management and requires that all inland and coastal waters
reach good status by 2015. It sets
demanding environmental objectives, including ecological targets for surface
waters.
The Environment Agency, which implements the Directive, will prepare a
River Basin Management Plan which will introduce controls to restore the rivers
and Broads to a good standard and the Authority will prepare a Supplementary
Plan for the Broads to augment this.
This Supplementary Plan will include measures for controlling diffuse
pollution.
The River Basin Management Plan must be published by December 2009 and
the Supplementary Plan is included as a 20-year aim in the Broads Plan.
For further information see www.defra.gov.uk/environment/water/wfd
The Internal Drainage Boards (IDBs), which produce and
implement drainage management plans, have an important role to play in terms of
catchment management and its effect on the wider area.
Specific
issues such as the behaviour of visitors to the Broads can be addressed to an
extent through education and discussion and the Authority seeks to do this,
whilst the Environmental Stewardship Scheme offers incentives to farmers to
improve environmental practice, including reducing diffuse pollution from
sediment run-off or leakage of slurry.
The Authority is also undertaking a three year project to address
diffuse pollution in a number of the Broads lakes, including mud pumping and
reconstituting reed margins on a number of the Broads, to increase the chances
of naturally functioning water environment.
Whilst these measures will help to maintain or improve habitat value,
the Authority has less control over the impact of development beyond the Broads
Authority boundary. It can seek to
influence adjacent Councils to ensure that policies are in place which cover
development which would have a significant impact on the Broads, however their
inclusion in the LDF and subsequent interpretation is a matter for the Districts.
The RSS identifies a Broads
sub-region which is wider than just the land within the Authorities boundaries
and includes parts of adjacent Districts.
The objectives in this sub-region include the protection and enhancement
of the waterways, which would include reducing the risk of pollution. In response to the problems potentially
associated with development beyond the boundaries of the Authority,
consideration could be given to the identification of a zone of hydrological
protection to protect the Broads from development in adjacent Districts which
would have an adverse impact on water quality.
In order to progress such an
approach it would be necessary to work in close co-operation with the adjoining
Districts and identify the zone within the relevant Local Development
Documents.
It
is recognised that the high level of protection accorded the Broads will enable
the Authority to deliver the vision of the special place, but regard must be
had to other interests too. Further,
not all development and use of land can be addressed by the Authority,
including development beyond the Authority’s area, so there is a need to work
with partners and other agencies to achieve the objectives.
DEVELOPMENT, THE ECONOMY AND
SUSTAINABLE COMMUNITIES
The
economy in the Broads is driven largely by the tourism industry, with an annual
value in 1998 of around £146.6M. The
hire boat industry is the single most important provider of holidays in the Broads,
accounting for 53% of trips by staying visitors in 1998 with these visitors
generating around 82% of the total tourism spend. The value of this income locally is of huge significance in
supporting local facilities, providing employment and sustaining communities.
Boatbuilding
is also a significant economic sector within the Broads and the region
generally - in the East of England, the British Marine Federation (BMF) data
shows that the total revenue from the leisure marine industry was £239.4M in 2002,
of which £141 million can be attributed to boat building, £36.9M to equipment
manufacturers and £10.9M to inland hire and charter companies.
Locally,
the BMF figures show that around 700 people are permanently employed in the
marine industry within the Broads area, increasing to 2000 overall (full-time
and part-time) when the surrounding hinterland is taken into account. These companies have a combined turnover of
£83M, some 27% of the East Anglian region and 4% of the national leisure marine
sector.
Agriculture
is the third main economy in the Broads, taking advantage of the flat and
fertile river valleys of the Broads area.
Much of the land is farmed under one of the agricultural designations
aimed at landscape
and/or
environmental conservation, which makes it vulnerable to change in response to
shifts in agricultural support policy.
The
Government objectives for rural areas are founded on the principles of
sustainable development and seek to achieve social inclusion, effective
protection and enhancement of the environment, prudent use of natural resources
and the maintenance of high and stable levels of economic growth and
employment. National policy set out in
Planning Policy Statement 7 ‘Sustainable Development in Rural Areas’ (PPS7)
states that Local Development Documents should:
“…. Facilitate and promote sustainable patterns of
development and sustainable communities in rural areas ... (including) policies
to sustain, enhance and, where appropriate, revitalise country towns and
villages (including through the provision of affordable housing) and for strong
diverse economic activity, whilst maintaining local character and a high
quality environment” (para 2).
There is a strong emphasis
in the Government guidance on the need for Local Development Documents to plan
pro-actively for economic development, community services and facilities and
housing for local needs, however it is also recognised that in nationally
designated areas such as the Broads the conservation of the natural beauty of
the landscape and countryside must be given great weight. In these areas, the emphasis is less on
promotion of growth and more towards facilitating the development necessary for
local well-being, both social and economic.
The emerging regional
policy reiterates this at a more local level.
Regarding economic development, it states that the strategy for the
wider Broads includes the need to:
“…
balance the economic regeneration needs of Great Yarmouth and Lowestoft with
the needs of the rural communities and the need to protect and enhance the
environment … (and) … Accommodate the regeneration of the Broads boat hire
industry …” (NSB1).
The supporting text to the
policy also comments that “ … the Broads is an area of restraint where no
significant housing growth is acceptable on the grounds of landscape and
environmental qualities and flood risk”.
The strategic policies set
out in the Norfolk Structure Plan (1999) seek to promote economic growth and
provide local employment opportunities consistent with the need for sustainable
development (EC1). The main focus for
employment growth is in towns and urban areas, however the needs of the rural
communities are recognised, particularly given the role of employment in the
maintenance of sustainable and viable communities. In rural areas, the strategy is to encourage rural enterprise and
diversification, with particular emphasis on strengthening and diversifying the local economy in areas
with designations for national or European economic assistance. Areas (EC4).
The Suffolk Structure Plan
(2001) recognises the challenges facing the rural economy and proposes to
address these through a positive approach to diversification. It refers to national guidance which
emphasises the importance of focusing development on existing towns and
villages thereby strengthening their local economy and sustaining local
services whilst protecting the open countryside and reducing the need to
travel. The Plan therefore sets out
policies to allow for both the re-use and adaptation of existing buildings
(ECON2) and the introduction of appropriate new development for employment
purposes (ECON4), to assist diversification in an environmentally sustainable
way.
It also recognises the
threat to rural facilities and states:
“Proposals
for new community facilities in keeping with the character and scale of
villages will be encouraged where there is no material conflict with
residential amenity or with policies for transport or protection of the
environment. Development that would result in the complete loss of a particular
type of community facility from a village will not be acceptable unless it can
be demonstrated that the facility cannot be made viable in the foreseeable
future” (ECON11)
The Broads Local Plan
(1997) contains policies which support economic development which is compatible
with protecting and enhancing the Broads environment, and offer encouragement
where development can take place which can strengthen the economic base without
damage to the landscape, waterways, wildlife and built environment. The policies are mindful of the Broads
Authority objective to retain boatyard sites in boatyard use where possible,
and any alternative use should not prejudice a future return to boatyard use.
The Broads Plan Guiding
Principle 11 recognises the need to develop and maintain high and stable levels
of economic and social prosperity, stating:
“Economic
and social development will focus on sustaining thriving rural communities
through key sectors, such as tourism, marine industry and agriculture, based on
the distinctive features of the Broads’ natural and cultural resources. These features include the waterways and
their adjacent settlements, fens and grazing marshes, together with associated
local traditions, crafts, skills and social culture. High quality, innovative developments that respect the special
qualities of the Broads while addressing contemporary needs will be
encouraged”.
.
Consultation - what you told us
Consultation
on the key issues to be addressed in the Core Strategy suggested the following
issues which were raised in the preparation of the Broads Plan:
·
Addressing social inclusion and access
·
Promoting the health of the local economy
·
Supporting economic regeneration and sustainability
·
Addressing the future of the hire boat industry and local
business in general
·
Provision of community facilities and services
Consultees were asked for
their views on these issues and whether there were further factors that the
Authority should be looking at.
Consultation
responses indicated that the key issues are the protection of the local economy
in general and the boat building and hire industry in particular. The decline in the traditional Broads
boating industry is identified as a priority to be addressed in order to
improve viability and maintain the ability of the Broads to offer a tourism product
which underpins many local communities.
This is identified as an issue in both the short term, and the long term
where the future of the tourist ‘product’ and the boating industry in general,
and the impact of change, will have on the nature and character of the Broads
economy.
The
Authority is committed to the support and promotion of the local economy – this
is set out in regional policy and in the Broads Plan and it is recognised that
in order to achieve sustainable communities there is a need for a thriving
local economy. The Core Strategy will
need to set out how the Authority will seek to protect and regenerate the local
economy in general and the boating industry in particular, whilst protecting
the special qualities for which the area is designated.
The Authority is already
engaged in the support and promotion of the local economy, particularly the
boating industry, through a number of initiatives including the Broads Boating
Holidays Project, and the Core Strategy will seek to develop and build upon
this work.
The issues of the holiday
industry in particular are also addressed in the chapter on ‘Recreation and
Tourism’ in this Report.
Historically,
the Broads Local Plan policies have sought to retain boatyards in boatyard use
and there has been a general presumption against redevelopment for alternative
uses. The justification for this has
been to retain and maintain the special character of the area and the balance
between water- and land-based opportunities for recreation. There have, however, been significant
changes in the holiday industry, including patterns of leisure, customer
expectations and an increase in short breaks, and this has coincided with a
period of decline in the traditional Broads holiday.
OPTION DESC1: Should the Core
Strategy permit any redevelopment on boatyard sites?
Broads Boating Holidays Project
In the late 1990s,
in response to concerns about the falling demand for boating holidays and at
the request of the Broads Hire Boat Federation, the Authority commissioned a
detailed study of the boating industry from consultants Strategic Leisure. The Study identified a number of problems
affecting the holiday experience on the Broads including standards of customer
care, quality of infrastructure, moorings etc., quality of on-shore services
and catering, condition of some holiday boats and availability of and access to
off-boat entertainment and attractions
Following the Study,
a detailed three year action plan was developed involving public and private
sector partners. The objectives were to
improve the visitor experience and long term prospects for the industry, by
addressing the identified shortcomings.
A number of measures have since been implemented, including the adoption
of a Quality Grading scheme for boats and a Quality Charter for on-shore catering
businesses and the improvements are on-going.
For further information
see www.broads-authority.gov.uk
and follow the links to ‘Boating’
The
majority of boatyard sites are within areas that are identified as at risk of
flooding and this will be a constraint to alternative uses in many
locations. The Authority is also
mindful that the boatyards themselves support ancillary industries and
operators within the wider Broads area and the impact of change will not
necessarily be limited to the yards alone.
This will need to be taken into account in determining appropriate
alternative uses.
Possible
alternative uses might include accommodation, uses which generate local
employment and income, uses which are related to the water and ancillary to
boating or uses which retain part or all of the boating infrastructure. The consultation responses received
identified the use of such sites for housing or shore-based leisure facilities
as options.
OPTION DESC2: What
redevelopment is appropriate and should this be identified on a criteria- basis
or should the Core Strategy set out appropriate forms of uses?
The Economic Impact of Diversification
Figures from the
British Marine Federation indicate that the boatyards in the Broads draw
services from across Norfolk and Suffolk, supporting the concern of the
Authority that the economic impact of diversification within the boatyards
would be felt in the wider Broads area and across a range of businesses.
In order to quantify
the value of boatyards to the wider Broads area, the Authority is commissioning
a study into the economic links between the related businesses and the extent
to which these support the local communities.
This will help to identify the extent to which areas are vulnerable to
change resulting from diversification and will inform the LDF process.
Support
of the local economy is not only about the boating industry and there are many
other businesses and operators within the Broads who rely on visitors and
residents for their livelihood. In the
longer-term, diversification of the economic base and the tourism ‘product’ may
offer the best opportunity to sustain local economic viability.
In
Great Yarmouth and Lowestoft, an Urban Regeneration Company has been formed to
promote regeneration and economic growth and this may have implications for
part of the Broads area which will need to be taken into account.
The
Great Yarmouth and Lowestoft area is also identified as a sub-region in the
draft RSS and the Strategy for the area includes objectives to promote
environmental industries including tourism.
OPTION DESC3: Should the Core
Strategy seek to promote diversification of the local economy and tourism
‘product’ and how is this best achieved?
Consultation
responses identified agriculture, as the third key component of the local
economy, after tourism and the boating industry, as an issues for the Core
Strategy. Agriculture is undergoing a
period of substantial change as a result of reforms to the support mechanisms
and these will have implications for the Broads. Support for agricultural diversification should seek to ensure
that the value of the landscape and conservation interest is maintained.
OPTION DESC4: Should the Core
Strategy support agricultural diversification, subject to protection of the
landscape and ecological interest?
In
addition to opportunities for local employment and a vibrant local economy,
sustainable communities need appropriate community facilities to support the
population. These facilities can also
offer benefits to visitors and can help to generate local income. Community facilities can be vulnerable to
change, particularly in areas or times of high land values when there is
pressure for redevelopment. Community
facilities can cover a broad spectrum of uses – from village halls and public
toilets to public launching facilities and open space.
The
Broads Local Plan protects some community facilities from change, whilst
supporting extensions to existing facilities or uses where this would not
impact adversely on the special character of the area. The consultation responses identified the
provision of community facilities as an issue for the Core Strategy.
It
should be borne in mind that the Authority boundary is drawn tightly around the
settlements and much of the built development within a village, and the land
potentially available for development is outside the Authority boundary. In order to achieve the provision of
facilities beyond the Authority area but which would benefit whole communities
it would be necessary to work in close co-operation with the adjoining
Districts. The location of sites within
the flood risk area and the availability of resources to fund such provision
are potentially constraints and it would be necessary for the Core Strategy to
identify how the objectives were to be achieved.
OPTION DESC5: Should the Core
Strategy identify necessary community facilities and sites for their provision?
Parish Plans
Parish Plans were
announced in the 2000 ‘Rural White Paper’ which set out the Government’s plans
for the countryside and have since been the subject of guidance for preparation
from the Countryside Agency. They are
intended to develop previous work such as village appraisals and village design
statements and set a framework for communities to plan their own futures.
They are holistic in
scope and set out a vision for a how the community wants to develop, and
identify the action needed to achieve it.
They can include everything that is relevant to the people who live and
work in the community, from employment and playgrounds to the design of new
buildings and protection of hedges and ponds.
They are prepared by the community for the community.
There are over 100
parishes in the Broads, of which around 15 have prepared or are preparing
Parish Plans and these will help the LDF to identify where new facilities or
improvements are required.
For further
information see the Countryside Agency document ‘Parish Plans – Guidance for
parish and town councils’.
The
current Broads Local Plan, in common with most Local Plans, seeks to locate new
development within existing settlements and identifies development boundaries
within which such development will be permitted subject to satisfying all the
other policies in the Plan. The purpose
of this is to protect the countryside from inappropriate development and to
promote sustainable patterns of development by concentrating development in
locations with local facilities and access.
Whilst
the principles and purposes of the approach are supported, there is concern
that restricting development only to these areas can result in over-development
and cramming and gives rise to pressure for building on open spaces, both
informal and formal, which have an important function in the built landscape by
breaking up groups of buildings.
An
alternative approach would be to adopt a criteria-based policy taking account
of the impact on factors including the local landscape, nature conservation
interest, adequacy of access and compliance with general sustainability
principles. In practice, such an
approach would retain the presumption against development in the open
countryside, but would allow greater flexibility to address local need.
OPTION DESC6: Should development
be restricted to within settlement boundaries or is it appropriate to permit
any sort of development elsewhere?
OPTION DESC7: Should appropriate development outside the
settlement boundaries be defined thorough criteria or on a site specific basis
or on the basis of use-types?
TOURISM AND RECREATION
One of the statutory
purposes of the Broads as a National Park is the promotion of the enjoyment of
the area by the public and the Broads is of national importance for its
recreational value and tourism makes a major contribution to the local
economy. An East of England Tourist
Board study showed that the overall value of tourism to the Broads in 1998 was
about £146.6M and that this supported the equivalent of 3,107 full-time jobs.
As a major tourist
destination, British Marine Federation figures show that the wider Broads area
contributes 35% of the national revenue for the inland hire and charter sector
within the industry.
There have, however, been
major changes to the pattern of tourism in recently years, in particular the
hire boat fleet has halved since the mid- 1980’s. Addressing these changes is a major challenge.
Policy context
National policy on tourism
is set out in Planning Policy Guidance Note 21 ‘Tourism’ (PPG21). It recognises the importance of tourism to
the national economy and seeks to support this. It does also recognise, however, that there is a need to respect
sustainability limits to prevent damage to the environmental resources on which
a thriving tourism economy will depend.
This has led to the development of four guiding principles on tourism:
- “supporting the development of the
industry in ways which contribute to, rather than detract from, the quality of
the environment;
-
promoting the
understanding of environmental quality concerns within the industry and of the
need to improve the quality of its service and its products;
- ensuring through the regional tourist
boards and Training and Enterprise Councils that managers in tourism adopt
visitor management techniques that can mitigate the impact on the environment;
and
- encouraging those types of tourism which
in themselves aim to safeguard the environment.” (para 3.15)
These guiding principles
with their emphasis on sustainable development are in accordance with the
statutory purposes of the Broads Authority, which include the need to conserve
and enhance the natural beauty of the Broads whilst also promoting the
enjoyment of the Broads by the public.
Specific national advice on
the inland waterways advises that the Government is keen to promote inland
waterways, both as part of the country’s national heritage and as a
resource. With respect to tourism,
Government advice in ‘Waterways for Tomorrow’ (DEFRA 2000) states:
“…
We will encourage their greater use for recreation; increased access for the
young, disabled and disadvantaged; and better communication with the widest
possible range of users”
Draft regional policy
recognises that tourism is one of the region’s key economic sectors, it also
notes that it is projected to make one of the highest contributions to the
absolute increase in the region’s gross domestic product. Whilst the policy retains a commitment to
sustainable development and tourism, it is more development focused and states
that local development documents should:
“include policies to encourage
investment in the maintenance, improvement and appropriate diversification of
the region’s tourist industry. This
investment should be based on maximising the benefits to, and minimising
negative effects on, the natural and built environment, local distinctiveness
and host communities;
…
promote development that encourages
more sustainable tourism including: the
co-ordination of activities and accommodation to minimise the need to travel;
enhancing existing facilities and/or re-using existing buildings; the
regeneration of seaside resorts; extending employment outside the normal
tourist season; regeneration (rural and urban); or urban renaissance ..” (E13).
The supporting text
recognises the conflicts that large scale tourism can bring and advises that
particular attention should be given to such development in sensitive areas,
warning
“Significant
growth in visitor numbers in such areas can have lasting effects on the natural
and historic environment and it is in the interests of tourism developers to
conserve the environment on which they rely”.
The overall strategic
policy for tourism in Norfolk in the Structure Plan (1999) is to strengthen and
diversify the tourism industry, maintain and increase employment in the tourist
industry and encourage regeneration, enhance the quality of visitor facilities
whilst controlling development to moderate visitor pressures in the most
sensitive areas and encouraging sustainability in facilities and access to them
(EC7).
The policy recognises that
increased visitor pressures could threaten the character of the area, including
the Broads and comments that
“The
aim is to maintain a balance between development, landscape, conservation and
community interests. In this way the
tourism industry can contribute in a positive way to the social and economic
well-being of the local community and also help to preserve the natural
resource of the countryside”.
Tourism development which
would have an adverse effect on the character of the Broads area is not
permitted (EC9).
The Suffolk Structure Plan
(2001) recognises the potential conflict between tourism development and
landscape and conservation objectives, particularly in sensitive designated
areas. It notes that the need to
resolve such conflicts is underlined by the degree to which the tourist
industry is based upon the county’s natural and built heritage. Subject to satisfaction of wider
environmental protection policies, it will permit development for tourist accommodation
in areas including where this will extend the holiday season or increase
facilities, provide employment in areas in need of economic assistance or
offers environmental or regeneration benefits (ECON12).
Regarding tourist
development in the countryside, it states:
“The
development of tourist accommodation in the countryside in cabins, chalets,
caravans and camping sites may be acceptable where there is no material
conflict with policies for transport or protection of the environment. It will
not however be appropriate: (a) in the Dedham Vale AONB; (b) adjoining the
estuaries of the Suffolk Coast and Heaths AONB; (c) in the Heritage Coast”
(ECON14)
and
“
… in the Broads, Heritage Coast, the estuaries of the Suffolk Coast and Heaths
AONB and Dedham Vale AONB, small-scale recreation facilities will be acceptable
where there is no material conflict with policies for transport or protection
of the environment. Such proposals will be encouraged where they replace
facilities in unsatisfactory locations or significantly lessen existing
conflicts” (REC3).
And in respect of
water-side development it permits the development of new marinas and yacht
harbours and associated facilities within towns, particularly on existing
derelict, redundant or underused water frontages, where there is no material
conflict with residential amenity or with policies for transport or protection
of the environment (REC4).
The objective of the
tourism and recreation policies in the Broads Local Plan (1997) is to stress
the importance of tourism in the local economy, but to ensure that the
development associated with this does not cause significant damage to the
environment which visitors come to enjoy.
Whilst large-scale development of accommodation or facilities is
considered to be inappropriate, policies do allow small-scale schemes and
proposals for development related to conservation and public enjoyment are
encouraged.
The Broads Plan also
recognises that tourism drives the economy in the Broads, benefiting hire boat
operators, shops, restaurants, hotels, cafes and attractions catering for
visitors and providing local communities with both income and employment. Changes, and particularly decline, to the
patterns of tourism will inevitably have an impact on these communities. The Broads Plan also recognises the
potential for conflict between visitor numbers and the protection of the
environment and the need for development to be sensitive and sustainable.
The
Broads Plan Guiding Principle 4 states:
“Tourism will be of a high standard,
catering for a range of needs that are consistent with the special features of
the Broads. It will contribute
significantly to sustaining thriving local communities while taking into
account the interests of others not involved in tourism who live or work in the
Broads”.
Whilst the value of tourism
is recognised, there is also an awareness that the pattern and level of tourism
in the Broads has been changing over the last 20 years or so and this has had
an impact on the structure of the holiday industry. This is partly due to competition from overseas destinations,
though changing customer demands is a contributory factor.
The Broads may be all about
water, with most activities relating to it in some way, however there is still
much to be enjoyed on land and this can offer the opportunity to disperse and
absorb some of the visitor pressure as well as offering a different way to
enjoy the Broads landscape. The
diversification of the tourism base would also increase its robustness and
resilience in the face of change.
Consultation
on the key issues to be addressed in the Core Strategy suggested the following
issues which were raised in the preparation of the Broads Plan:
·
Managing development pressures related to visitors and
tourism
·
Integrating/reconciling the needs of recreation and
conservation
·
Protecting public and parish staithes
·
Addressing the shortage of short and long term moorings
·
Managing sport and activities in the countryside
·
Improving the quality of the physical infrastructure (river
frontages, access points, hire boats)
·
Ensuring sustainability of the tourism industry
·
Promoting diversification within the tourism industry
Consultees were asked for
their views on these issues and whether there were further factors that the
Authority should be looking at.
Consultees
supported the objectives and issues listed as being those that the Core
Strategy will need to address. As a key
priority, the need to balance the tourism industry requirements with the statutory
responsibility to protect the natural beauty and distinctiveness of the area
was reiterated. This reflects the
purposes of the Authority as set out above and is identified broadly in the
Vision. Achieving the objectives of
supporting the tourism and recreation industries, which underpin the viability
of the local economy, without impinging on the natural beauty and ecological
value of the Broads is a challenge which the LDF will need to address
OPTION TR1: In considering tourism and recreational
development should the Core Strategy adopt criteria-based policies which apply
equally across the Broads and give priority to the protection of landscape and
nature conservation value?
Across
the Broads, there is considerable variation in landscape types and ecological
sensitivity, with some areas more sensitive and vulnerable to change than
others. Similarly visitor pressure is
not evenly spread across the system, with some areas being ‘honeypots’
particularly in the height of the season, whilst other areas remain relatively
quiet. Two thirds of the hire boat
activity is concentrated in the northern rivers (Rivers Bure, Thurne and Ant),
whilst the southern rivers (Rivers Yare and Waveney) are quieter by comparison.
OPTION TR2: Should the Core
Strategy seek to steer tourism and recreation development away from the more
sensitive areas and encourage development elsewhere where the system is more
able to accommodate growth?
Changing
patterns of tourism
There have been
significant changes in the level and pattern of boat use on the Broads,
particularly in the last 10 years, with a reduction in the number and duration
of hire-boat based holidays. This has
led to a decline in the number of boats in the fleet of 33% between 1994 and
2004 to give a total of 1243 hire boats and day launches. The overall number of boats on the water
has, however, increased due to the growth in private ownership. In response to this and the need to service
the private craft, some boatyards have diversified into marina and other
support services; other boatyards have closed.
In
addition to support for the tourism and recreation industry, consultees
identified the need to adapt to the changes over the last 25 years and respond
to these whilst taking a longer-term view of the tourism product in order to
manage change positively. This will
mean promoting improvements to the quality of the existing product and
exploring diversification to take advantage of new opportunities. This might include an increased level of
shore-based accommodation and facilities or activities, although these will
need to comply with wider sustainability objectives which will be a constraint
in some of the more isolated locations.
This issue has been raised in the ‘Development, the Economy and Sustainable
Communities’ chapter above.
In
planning for change and, particularly, when specifying uses, it must be noted
that the leisure sector is a fast-changing industry and the patterns and
popularity of uses will alter over time.
Whilst the Broads may be the National Park in the area,
Norfolk and north Suffolk have many other attractions to offer the visitor,
including the North Norfolk Coast Area
of Outstanding Natural Beauty (AONB)and the established holiday resorts at
Great Yarmouth and along the coast, whilst Norwich is an attractive, medieval
city.
There are opportunities to make better links between these
destinations and the Broads which would extend the range of facilities and
experiences available to the visitor and strengthen the local economies. The promotion of heritage has been shown to
have a key role in increasing tourism and encouraging regeneration. The wealth and variety of the built, historic
and cultural landscape within the wider area represents a significant asset
which should be promoted to complement the natural beauty for which the Broads
is renowned.
There
are opportunities other than those offered by boatyard regeneration, other
activities which are compatible with the ethos of ‘promoting opportunities for
the understanding and enjoyment of the special qualities of the Broads by the
public’ which could be explored and encouraged in a more pro-active way. Issues that have arisen as a result of the
consultation include provision of additional navigation space and improved
facilities for anglers.
It
is noted that improvements to the quality of the physical infrastructure and
provision of amenities and facilities would also help to address the social and
recreational needs of residents of the Broads as well as visitors and
contribute towards the development of sustainable, vibrant communities.
OPTION TR3: Should the Core
Strategy assess the extent to which tourism and/or recreational demand is being
met and identify measures to address this, including extending the range of
activities where appropriate?
OPTION TR4: Should the Core Strategy specifically
identify additional tourist facilities and activities which are compatible with
the ethos of the Broads and identify sites for these within the area?
One of the key issues that has arisen as part of the consultation is
the shortage of moorings within the Broads system, particularly short-term
visitor moorings. The Authority is
currently carrying out an extensive moorings survey and this work will inform
the Core Strategy by enabling the Authority to quantify areas of mooring and
identify where additional provision is required.
If the Authority is to identify areas where additional mooring is to be
provided, the means for achieving this will need to be included in the
LDF. Some may arise through development
at waterside sites, and there may be opportunities under BFAP. Opportunities for the latter are being
explored, but it is likely that the Authority will need to fund some of the
additional provision directly so it will be necessary to set priorities.
The protection and retention of parish and public staithes, including
within boatyards, will help to maintain access to the Broads villages from the
river and offer recreational opportunities for residents. The protection of these facilities has been
raised as an issue and the Authority is committed to investigation of this and
the preparation of a dinghy and slipway strategy.
OPTION TR5: Should the Core
Strategy identify areas where additional mooring is required?
Mooring Survey
The number of public
moorings across the Broads has been in decline for a number of years. This includes short- and long-term moorings
and informal spaces. The reasons include
the conversion of boatyards to alternative uses, the increase in private boats
which occupy formerly publicly available spaces in boatyards and, more
recently, engineering works associated with the flood defence works. Lack of mooring will affect the visitor
experience by limiting the places that can be visited and will tend to
concentrate visitor numbers where mooring is most plentiful, which can cause
problems in terms of promoting quiet enjoyment.
This is a major
issue to be addressed by the Authority and has been identified as a
priority. An initial map-based survey
has been undertaken identifying current provision on the river and Broads
system, with a further questionnaire survey to identify additional provision
within boatyards. The questionnaire
also asks boatyards owners about their plans for the future of their moorings,
so that projections can be made, and asks them to identify where they consider
additional capacity is required.
The conclusions of
the mooring survey will be used to inform the LDF and enable the Authority to
develop an appropriate Mooring Strategy.
Angling Slipway Strategy
Historically most of
the parish staithes would have had a slipway for use of residents, however over
time many of theses have been lost through redevelopment, change of ownership
or neglect. This affects the ability of
communities to access the water and for visitors to access the shore.
A review was
undertaken to establish the extent and availability of slipway provision for
small craft on staithes and within boatyards.
The Angling Strategy Group, which comprises representatives from the
Authority, the Environment Agency, English Nature and angling groups, was
involved with the development of the data.
The conclusions of
the survey will be used in the development of a strategy to protect the
remaining slipways and implement enhancements where possible, for example to
access, parking and infrastructure. It
will also seek to create new slipways or re-open old ones where possible, and
will link in with the flood defence project.
In developing policies for
tourism and recreation, the Core Strategy will need to ensure that proposals or
policies meet the tests of sustainability.
Whilst the Core Strategy will be seeking to promote economic
sustainability this must not be at the expense of environmental sustainability
and where there is conflict the environmental considerations will take
precedence due to the statutory purposes of the Authority.
It
will therefore be necessary, in determining policy, to evaluate the location of
main attractions/activities and concentrate additional facilities and
attractions in most sustainable locations.
Typically, housing
development in the Broads comprises primarily replacement dwellings or
conversion to dwellings and small infill development. This applies both to permanent residential properties and holiday
accommodation. A small number of new
houses are permitted each year. A major
constraint on housing development, particularly on small infill sites, is flood
risk and there is a presumption in the Broads Local Plan against development on
such sites unless it is providing for local housing need or is necessary for
agricultural, forestry or boatyard staff.
Holiday accommodation may also be appropriate in the flood plain due to
the differing patterns of use.
On average, the Broads
Authority permits around 35 – 40 units of housing per annum.
Policy context
Nationally, housing is a
priority topic. The ODPM has launched a
five year plan entitled ‘Sustainable Communities: Homes for All’ (ODPM 2005)
which contains measures to offer greater choice and opportunity in housing,
with the explanation that:
“A
flourishing, fair society based on opportunity and choice for everyone depends
on creating sustainable communities – places that offer everyone a decent home
that they can afford in a community in which they want to live and work, now
and in the future”.
These measures includes the
need to increase the supply of housing for sale and for rent.
National planning policy
for housing is set out in Planning Policy Guidance Note 3 ‘Housing’
(PPG3). The objectives include policies
to ensure that local planning authorities plan to meet the housing requirements
of their communities and create more sustainable patterns of building. It identifies previously developed land and land
within or adjacent to existing centres and close to public transport nodes as
suitable locations for housing development and advises that policies should be
prepared to provide for affordable local housing for local needs where there is
a demonstrable deficiency.
The advice in ‘Sustainable
Communities: Homes for All’ regarding
rural areas, which will not meet the sustainability criteria contained in much
of the policy guidance, states:
“It is important that there is adequate
housing provision in rural areas to meet the needs of local people and to
contribute to the delivery of sustainable communities … Local planning
authorities should make sufficient land available either within or adjoining
existing rural communities to enable these requirements to be met in a manner
which contributes to the achievement of sustainable communities. Affordable housing provision in rural areas
should be supported by a rural exception site policy. Rural exception sites should be small, solely for affordable
housing and on land within or adjoining existing small rural communities which
would not otherwise be released for general market housing”.
Regional policy as set out
in the draft regional strategy promotes a high level of new housing development
regionally to achieve the objectives set out in the Sustainable Communities
Plan and adopts a sequential approach to appropriate sites . It does identify the need for more
affordable housing in rural areas and states that Local Development Documents
will:
“ … require provision of a range of
dwelling types and sizes to meet the assessed need of all sectors of the
community based on up-to-date local housing needs studies .. (and) .. secure an adequate supply of
affordable housing consistent with local assessments of need .. (and) .. ensure
that where affordable housing is secured it will be available in perpetuity or
for an appropriate period to be set and secured by planning agreement …” (H2).
There is, however, an
understanding that interpretation of the above requirement will vary across the
region according to local circumstances and the supporting text to the
sub-region policy NSB1 covering the Broads states:
“…
The Broads is an area of restraint where no significant housing growth is
acceptable on the grounds of landscape and environmental qualities and flood
risk” (para 5.85).
The
Norfolk Structure Plan (1999) identifies the main locations for major housing
provision in the County as being in the major urban areas and selected towns
(H3 & H4). This sequential approach
seeks to promote more sustainable patterns of development and housing in
smaller towns and villages will only be permitted on a small scale where they
enhance the form and character of the settlement (H7). In the countryside housing development will
only be permitted where it is shown to be needed in connection with
agriculture, forestry, organised recreation or tourist facilities, and it could
not reasonably be provided within a settlement and there are no significant
environmental or access concerns (H8).
Exceptions may be permitted for affordable housing, subject to criteria
including access to services (H9).
The
Suffolk Structure Plan (2001) adopts a sequential approach to housing, which is
to be located in the main in existing settlements (CS3 & CS4). It refers to the established policy of
restraint on new development in the open countryside away from settlements, in
the interests of agriculture, rural amenity, road safety, and economy in
service provision, stating that the only exceptions should be to meet the needs
of personnel employed in agricultural (including animal husbandry),
horticultural or forestry, with the only exception being where there is proven
national interest and a lack of alternative sites (ENV6). Exceptions may be made for affordable
housing (CS9).
The current Broads Local
Plan (1997) does not allocate areas for housing; given the size of the area and
the special character this has not been considered appropriate or necessary,
instead there are policies against which applications for housing – both
permanent residential and holiday accommodation – are considered. Applications are judged on their own
merits. There is a general presumption
against housing outside the development boundary other than where it meets a
specific, local need or is a replacement or conversion; in each case the
proposal must also meet other criteria including appropriate scale and
design. Affordable housing is
identified as appropriate outside development boundaries where a need has been
identified and which cannot be located within settlements, subject to meeting
design, wildlife conservation and amenity criteria.
The Broads Plan prioritises
the maintenance of economically and socially thriving communities in Guiding
Principle 11 which states:
“Economic and social development will
focus on sustaining thriving rural communities through key sectors, such as
tourism, marine industry and agriculture, based on the distinctive features of
the Broads’ natural and cultural resources.
These features include the waterways and their adjacent settlements,
fens and grazing marshes, together with associated local traditions, crafts,
skills and social culture. High
quality, innovative developments that respect the special qualities of the
Broads while addressing contemporary needs will be encouraged”.
Achievement of this
objective will require the provision of housing to meet local needs and
maintain stable, vital communities.
These needs may include both permanent housing for local residents and
accommodation for holiday makers where this would contribute to the maintenance
of the local economy.
Consultation
on the key issues to be addressed in the Core Strategy suggested the following
issues which were raised in the preparation of the Broads Plan:
·
The impact of second homes
·
Provision of affordable housing
·
The impact of development beyond the Broads Authority
boundaries
·
Housing in flood plain
Consultees were asked for
their views on these issues and whether there were further factors that the
Authority should be looking at.
Consultees supported the issues listed
as being those that the Core Strategy should address, with affordable housing
to sustain local communities identified as a key priority. A number of respondees have put forward
sites and asked that they be included for development in the LDF.
Historically the Authority has not
allocated land for housing. In part
this is due to the nature of the boundaries of the area, which exclude the
major parts of settlements where most development can be accommodated, and in
part due to the character of the landscape which, being open, flat and
low-lying, is sensitive to new development, but primarily because it is not a
purpose for which the area was designated.
Notwithstanding
the comments made by consultees, it is likely that the majority of residential
housing, both general market and ‘affordable’, will be provided in those parts
of settlements beyond the Broads boundary.
Land availability and suitability, with most of the area within the
Broads being constrained by flood risk, will dictate this. There may, however, be sites within the area
which may be suitable for housing, though these are likely to be small and
appropriate only for a limited number of dwellings and it will be necessary to
determine the type of housing that is most needed.
Were
the Core Strategy to adopt an allocation approach, it is likely that it would
identify only general locations for such development, with detailed allocations
made in a subsequent DPD.
OPTION H1: Should the Core Strategy identify land for
‘affordable’ housing?
OPTION H2: Should the Core
Strategy identify land for general market housing?
An alternative approach to the provision of housing would be to retain
the criteria-based approach in the Broads Local Plan, with criteria set for the
different types of tenure. This would
allow sites to be assessed as and when they came forward as an application.
OPTION H3: Should the Core
Strategy adopt a criteria- based approach to the provision of housing, both
general market and affordable?
Consultation responses with
regard to second homes, which is an issue due to the potential for impact on
housing availability and local communities, were mixed, with there being more
support for discouraging rather than encouraging further such development. Other National Park Authorities have adopted
a policy restricting ownership of new housing to local people only as a means
of sustaining communities and facilities and controlling the increase in house
prices. It would also help to balance
the conflict between the need to support essential housing for local need and
the pressure for large luxury homes.
OPTION H4: Should the Core
Strategy restrict ownership of new housing to local people only?
Local Occupancy
Conditions
Most
National Park Authorities in England now apply ‘local occupancy’ conditions to
new build properties in parts of their areas to ensure that new housing will
address local rather than external demand.
People intending to live in such dwellings, both initially and
subsequently, are required to prove that they meet a number of criteria such as
that they have resided permanently in the National Park for the last three
years and are in need of new accommodation or do not live in the National Park,
but have a longstanding link to the local community or have an essential need
from age or infirmity to move to a village to be near relatives who have been
permanently resident within the National Park for three years or have an essential
need to live close to their work in a parish within the National Park.
The
Broads Local Plan adopts a similar approach with respect to new dwellings for
staff connected with agriculture, forestry, boatyard and tourist enterprises,
where occupancy is restricted to use in connection with employment at those
operations only.
The
importance of holiday accommodation for the local economy, particularly its
role in helping to reverse the decline in the traditional Broads holiday
industry, has been referred to elsewhere in this Report and there is likely to
be a continuing demand for such development.
As for affordable and general market housing, the Core Strategy could
identify suitable sites, or adopt a criteria-based approach as existing.
OPTION H5: Should the Core
Strategy identify land for holiday accommodation or adopt a criteria-based
approach?
Finally,
consultees raised the issue of the impact of development beyond the Broads
Authority boundary. With regard to
housing, this can offer benefits, in that it could help to address local need,
but the scale of growth planned in the Norwich sub-region is substantial so
there are potentially negative impacts too.
It will therefore be important to work closely with neighbouring
authorities in order to minimise the impacts and ensure that the appropriate
infrastructure is in place.
ACCESS AND TRANSPORT
The
Broads area is crossed by a number of major transportation links, including the
A47 trunk road east of Norwich and the A12 south of Great Yarmouth, and a number
of other important roads, however as a predominantly rural area, access to the
villages, rivers and Broads is usually off minor roads.
Due
to the geography and network of waterways, much of the Broads area is also
relatively difficult to access and the best – and sometimes only – way to reach
many parts of the system is by water.
Moreover links between land and water-based recreational provisions are
limited.
Ninety-four
percentage of visitors to the Broads arrive by private car, causing seasonal
congestion during the summer travel period, particularly in and around towns
acting as a focus for attractions and which provide easy access to the rivers
or Broads. The result is increased
pressure on the area in terms of demands for visitor attractions,
accommodation, road space and parking.
This creates a contradictory impression to visitors who expect the
Broads to be tranquil and not an area of dense traffic and congestion.
Policy context
National policy on
transport is set out in planning Policy Guidance Note 13 (PPG13) which sets the
following objectives:
·
Reduce the need to
travel
·
Integrate planning and
transport
·
Promote more sustainable
travel choices, such as walking, cycling and public transport
This is developed in the
draft RSS which sets the following objectives :
·
Reduce the need to
travel
·
Make travel more
sustainable
·
Widen travel choice
·
Achieve a sustainable
relationship between jobs, home and services
·
Develop a sub-regional
approach to policy integration
·
Balancing housing/jobs
growth
·
Great Yarmouth and
King’s Lynn priority regeneration areas
·
Investment on strategic
road and rail network focused on inter-modal network and between Regional
Interchange Centres
·
Focus on growth and
regeneration areas
The strategy for transport
in Norfolk as set out in the Structure Plan (1999) seeks to encourage increased
sustainability of access. Mechanisms to
achieve this include the adoption of an integrated approach to transport
planning which encourages a modal shift towards public transport, cycling and
walking and the implementation of an appropriate locational strategy for
development (T1). It recognises the
challenges of providing for sustainable development and the need to strike a
balance between serving economic development,
protecting the environment
and maintaining the quality of life.
The Structure Plan also
sets out the requirement for a study to examine and implement improvements to
the A47 between Norwich and Great Yarmouth, including the Acle Straight; the
Structure Plan supports the dualling of this road (T9).
The strategic policies in
the Suffolk Structure Plan (2001) for transport and access set five key themes:
accessibility, economy, sustaining and enhancing the natural and built
environments and improving the quality of life for those affected by transport,
safety and integration by bringing together transport and land use planning to
reduce the need to travel and encourage mixed use development and encouraging
travel by sustainable modes by integrating public transport and promoting
appropriate measures. There are
specific policies for increasing walking and cycling by maintenance of existing
facilities and provision of new (T3), encouragement, facilitation and promotion
of public transport (T4) and implementation of traffic management schemes to
reduce the adverse environmental, social, health and safety impact of vehicular
traffic (T5).
The current Broads Local
Plan (1997) includes roads schemes affecting the Broads area which were
proposed for implementation at the time of the Plan’s preparation; some of
these schemes have now been completed and others superceded. It also refers to the duty of the Authority
to protect the Broads landscape, waterways and wildlife habitats, therefore the
Plan includes a policy to object to any road schemes which would be likely to
have a significant adverse effect on the landscape, wildlife, waterways or
built environmentof the Broads unless it were demonstrated to be in the public
interest (TC1).
The Plan also seeks to
encourage improved traffic management to benefit highway safety, environmental
improvement and visitor enjoyment and to promote cycling and public transport.
The Vision for the Broads
set out in the BATS is:
“To
provide a safe, secure and accessible transport system that supports
sustainable tourism, enhances the economic vitality and liveability of the
Broads area, whilst minimising the adverse impacts of transport and climate
change on the Broads’ unique environment”.
The Strategy identifies
accessibility to the Broads as an issue, particularly the lack of integration
between the various modes of transport which does not encourage visitors to
arrive or travel in a more sustainable manner and proposes improvements to
address this.
Congestion, similarly, is an issue which could be improved by greater use of
public transport and the Strategy seeks to revitalise the local railway network
and promote alternative modes of transport to reliance only on the private
car.
It also recognises that the
quality of the environment, which is the key attraction for most visitors, can
be compromised by the impacts of tourism and seeks to promote the development
and use of sustainable transport infrastructure.
Consultation
on the key issues to be addressed in the Core Strategy suggested the following
issues which were raised in the preparation of the Broads Plan:
·
Provision of transport infrastructure
·
Maintaining public rights of way
·
Promoting alternative access to the Broads – eg cycle ways
and footpaths
Consultees
were asked for their views on these issues and whether there were further
factors that the Authority should be looking at.
Consultees
supported the issues listed as being the issues relating to access and
transport to be addressed by the Core Strategy.
Access
to the Broads was raised as the priority issue, including the promotion of
increased and alternative access to the Broads using cycle, footpath and
boat. Historically, access around the
Broads and along the rivers has been restricted so that users of the water
system experience a sense of isolation, however there is clearly support for
the adoption of a more inclusive approach.
This
accords with the objective in BATS to improve walking and cycling facilities to
support the local economy and the diversification of the tourism industry. In certain locations, it would also support
the development of links between sustainable modes of transport and the
improvement of linkages and interchanges between all modes.
Any
improvements to access would take into account the needs of disabled people.
The
use of the waterways in this was raised, including the issue of re-opening
formerly navigable waterways to improve access and linkage and provide
additional recreational facilities.
These will, in themselves, have implications for access.
Broads Bike Hire Development Project
The Authority has sought to encourage access to the area by bicycle and
has developed a number of bicycle hire facilities in the main visitor areas
across the Broads. This promotes quiet
and sustainable access in a manner compatible with the National Park ethos,
whilst encouraging visitors to consider the impact of their activities on an
ecosystem vulnerable to climate change.
Such is the success that the Sustainable Development Fund, using monies
provided by DEFRA to the Authority for distribution through appropriate
projects, has recently provided an additional 60 bicycles at five hire centres
in the Broads to extend the initiative.
In
addition to the provision of new footpaths and cycleways, there is a need to
ensure proper and timely maintenance of existing amenities and this was an
issue that was raised.
OPTION AT1:
Should the Core Strategy seek to improve access to the riverside and
Broads by the introduction of additional footpaths and cycleways?
Related to the above, consultees raised the issue of improving the
access to the Broads by public transport and reducing the need for the private
car. This reflects issues raised in
BATS, which sets as an objective the improvement of train services between the
Norwich and Great Yarmouth sub-regions and improving the bus services. The Authority has supported the development
of the Broads Hopper bus service, which links the Broads and visitor
attractions in the surrounding area, and the Core Strategy could seek to
develop this further and establish similar links.
Were this option to be pursued it would be necessary to identify how
such a service would be funded and the support of partner organisations would
be required.
OPTION AT2:
Should the Core Strategy support the development of increased public
transport provision in the wider Broads area?
One of the main accesses into the Broads is provided by the A47 linking
the holiday towns of Great Yarmouth and Lowestoft and the eastern Broads to the
national road network. The improvement
of the Acle Straight between Ale and Great Yarmouth has been discussed for many
years. The A47 is a trunk road and
responsibility for its planning and construction would be a matter for the
Department for Transport, however, were such a scheme to come forward the views
of the Authority would be required. It
would be important to balance the need for the road, and the benefits particularly
in economic terms for Great Yarmouth and the surrounding areas, with the impact
on the Broads. Other measures which
might be taken to improve access to Great Yarmouth, including, for example,
improvements to public transport and measures within the town, would need to be
taken into account. A number of
consultees raised this as an issue for the Core Strategy to address in
principle.
OPTION 3:
Should the Core Strategy address the issue of improving access to Great
Yarmouth?
Thank
you for taking the time to read this report.
The views of stakeholders and local communities are very important in
the Local Development Framework process.
Please
respond to this consultation document by 14 October 2005.
Responses
should be sent to:
Policy Coordinator
Broads Authority
18 Colegate
Norwich
NR3 1BQ
Tel: 01603
610734
Fax: 01603 765710
Email:
LDF@broads-authority.gov.uk