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 requir