1

The Coal Authority is a non-departmental public body sponsored by the Department of Business, Energy & Industrial Strategy. As a statutory consultee, the Coal Authority has a duty to respond to planning applications and development plans in order to protect the public and the environment in mining areas.

As the administrative area of Greater Norwich lies outside the defined coalfield, the Coal Authority has no specific comments to make on any stages of your Local Plan process.

Thanks for consulting us.
The sites are not located near the Broads, so no real comments.

Wicklewood Parish Council welcomes the GNLP Consultation on Travellers and Gypsy sites and asks for any current and future planning applications for such sites within our parish to be refused unless the sites concerned have been considered by and approved through this consultation process.

Water Resources East Anglia is identified as an area of serious water stress. We strongly recommend that you require any new residential developments (not only for this consultation) are constructed to meet the optional higher water efficiency standard of 110 litres/person/day, as per Requirement G2 in Part G of the Building Regulations 2010.
GNLP5005 & GNLP5023
Foul Drainage Capacity
There is limited capacity at Wymondham Water Recycling Centre. The development is however small, but we would recommend that the constraints analysis is updated from green to amber for utilities capacity for this site.
Flood Risk/Permitting
This allocation borders the River Bays which is designated as a main river. Please note that a Flood Risk Activity Permit will be required for any development within 8m of this river. There are also Environment Agency maintained assets bordering this river (high ground) and this will most likely be taken into account in any permit application. We would require a strip of land to be left close to the river to allow access and avoid compromising the defences.
Contamination
In relation to contamination, this site resides in Source Protection Zone 3 (further information on SPZs can be found here Groundwater source protection zones (SPZs) - GOV.UK (www.gov.uk)) and is also on a principal aquifer. The site also overlies a historic landfill (Stayground Lane).
This would therefore trigger a consultation with us at the planning application stage. We would expect to see contaminated land assessments submitted as part of the application.
We have provided 2 consultation responses to planning applications on this site (under reference AE/2004/014191/06 and AE/2021/126063/01). The latter was South Norfolk DC application which can be found on their website under reference 2021/0607. You will see a desk study has already been produced. We would recommend taking a look at the outputs of this alongside our 2021 response.
In terms of Environment Agency comments in relation to contaminated land, we provide comments when sites have a ‘previously contaminative use’ as defined by the DoE Industry Profiles. A full list can be found here DoE Industry Profiles (claire.co.uk). We consider Waste disposal/treatment sites to be High Polluting Potential Previous Uses. I note that the site is also on a historic landfill sites and the Wymondham site resides within source protection zone 3. We would therefore expect to see contaminated land risk assessments submitted should the sites be brought forward. We are pleased to see that this is referenced as part of the site assessments for these sites. Any application should provide proportionate but sufficient site investigation information (a risk assessment) prepared by a competent person to determine the existence or otherwise of contamination, its nature and extent, the risks it may pose and to whom/what (the ‘receptors’) so that these risks can be assessed and satisfactorily reduced to an acceptable level. The National Quality Mark Scheme (NQMS) accredits competent persons with regard to assessing and reporting land contamination issues.
As with nearly all sites affected by contamination, most land contamination issues are surmountable with sufficient assessment and/or remediation (and as such, costs) if required. On this basis we would not rule out any development categorically on land contamination grounds at this stage. Whether or not it is economically viable however would be based on any risk assessments and cost benefit determination by any such developer.
Our main interest is when there is the breaking of ground. If the application is for the siting of caravans on this land it is likely to be of less concern to us. We would likely request that there should not be any piling or if necessary that a piling risk assessment is undertaken as piling can mobilise contaminants. We are also sharing the below SuDS informative which contains some useful guidance for these sites.
Advice to LPA on Sustainable Drainage Systems (SuDS) informative
1. Infiltration sustainable drainage systems (SuDS) such as soakaways, unsealed porous pavement systems or infiltration basins shall only be used where it can be demonstrated that they will not pose a risk to the water environment.
2. Infiltration SuDS have the potential to provide mobilise pollutants and must not be constructed in contaminated ground. They would only be acceptable if a site investigation showed the presence of no significant contamination.
3. Only clean water from roofs can be directly discharged to any soakaway or watercourse. Systems for the discharge of surface water from associated hard-standing, roads and impermeable vehicle parking areas shall incorporate appropriate pollution prevention measures and a suitable number of SuDS treatment train components appropriate to the environmental sensitivity of the receiving waters.
4. The maximum acceptable depth for infiltration SuDS is 2.0 m below ground level, with a minimum of 1.2 m clearance between the base of infiltration SuDS and peak seasonal groundwater levels.
5. Deep bore and other deep soakaway systems are not appropriate in areas where groundwater constitutes a significant resource (that is where aquifer yield may support or already supports abstraction).
6. SuDS should be constructed in line with good practice and guidance documents which include the SuDS Manual (CIRIA C753, 2015), Guidance on the Construction of SuDS C768 and the Susdrain website. For further information on our requirements with regard to SuDS see our Groundwater protection position statements (2018), in particular Position Statements G1 and G9 – G13 available at: https://www.gov.uk/government/publications/groundwater-protection-position-statements
We recommend that developers should
1) Refer to our ‘Groundwater Protection’ website;
2) Refer to our CL:AIRE Water and Land Library (WALL) and the CLR11 risk management framework provided in https://www.gov.uk/guidance/land-contamination-how-to-manage-the-risks when dealing with land affected by contamination, and also includes the Guiding Principles for Land Contamination for the type of information that we require in order to assess risks to controlled waters from the site. The Local Authority can advise on risk to other receptors, for example human health;
3) Refer to our Land Contamination Technical Guidance;
4) Refer to ‘Position Statement on the Definition of Waste: Development Industry Code of Practice’;
5) Refer to British Standards BS 5930:1999 A2:2010 Code of practice for site investigations and BS10175:2011 A1: 2013 Investigation of potentially contaminated sites – code of practice
6) Refer to our ‘Piling and Penetrative Ground Improvement Methods on Land Affected by Contamination’ National Groundwater & Contaminated Land Centre Project NC/99/73. The selected method, including environmental mitigation measures, should be presented in a ‘Foundation Works Risk Assessment Report’, guidance on producing this can be found in Table 3 of ‘Piling Into Contaminated Sites’;
7) Refer to our ‘Good Practice for Decommissioning Boreholes and Wells’.
8) Refer to our ‘Dewatering building sites and other excavations: environmental permits’ guidance when temporary dewatering is proposed
Waste Management Licences
Waste Management Licence 70519 is located on site. We would expect this to be surrendered as appropriate should waste operations cease.
GNLP5014, GNLP5019, GNLP5020, GNLP5021 & GNLP5024
Foul Drainage
This site does not appear to have access to mains drainage. Therefore, private means of foul drainage may be necessary. We would therefore suggest that the constraints analysis for ‘utlilities infrastructure’ is updated from green to amber.
Government guidance contained within the National Planning Practice Guidance (Water supply, wastewater and water quality – considerations for planning applications, paragraph 020) sets out a hierarchy of drainage options that must be considered and discounted in the following order which must be followed at application stage:
1. Connection to the public sewer
2. Package sewage treatment plant (adopted in due course by the sewerage company or owned and operated under a new appointment or variation)
3. Septic Tank
Foul drainage should be connected to the main sewer. Where this is not possible, under the Environmental Permitting Regulations 2010 any discharge of sewage or trade effluent made to either surface water or groundwater will need to be registered as an exempt discharge activity or hold a permit issued by the Environment Agency, addition to planning permission. This applies to any discharge to inland freshwaters, coastal waters or relevant territorial waters.
Planning and permitting are separate regimes so we would highlight that should this site be brought forward that there is no guarantee of the granting of an Environmental Permit. We would therefore recommend applicants contact us as soon as possible regarding the application for the relevant permits. Upon receipt of a correctly filled in application form we will carry out an assessment.
Domestic effluent discharged from a treatment plant/septic tank at 2 cubic metres or less to ground or 5 cubic metres or less to surface water in any 24 hour period must comply with General Binding Rules provided that no public foul sewer is available to serve the development and that the site is not within a Groundwater Source Protection Zone.
A soakaway used to serve a non-mains drainage system must be sited no less than 10 metres from the nearest watercourse, not less than 10 metres from any other foul soakaway and not less than 50 metres from the nearest potable water supply, spring or borehole.
Where the proposed development involves the connection of foul drainage to an existing non-mains drainage system, the applicant should ensure that it is in a good state of repair, regularly de-sludged and of sufficient capacity to deal with any potential increase in flow and loading which may occur as a result of the development.
Where the existing non-mains drainage system is covered by a permit to discharge then an application to vary the permit will need to be made to reflect the increase in volume being discharged. It can take up to 13 weeks before we decide whether to vary a permit.
We trust this advice is useful.

1. Anglian Water
1.1. Anglian Water is the water and water recycling provider for over 6 million customers in the east of England. Our operational area spans between the Humber and Thames estuaries and includes around a fifth of the English coastline. The region is the driest in the UK and the lowest lying, with a quarter of our area below sea level. This makes it particularly vulnerable to the impacts of climate change including heightened risks of both drought and flooding, including inundation by the sea.
1.2. Anglian Water has amended its Articles of Association to legally enshrine public interest within the constitutional make up of our business – this is our pledge to deliver wider benefits to society, above and beyond the provision of clean, fresh drinking water and effective treatment of used water. Our Purpose is to bring environmental and social prosperity to the region we serve through our commitment to Love Every Drop.
2. Anglian Water and Local Plans 2.1. Anglian Water is is the statutory water and sewerage undertaker for the Greater Norwich Local Plan (GNLP) area and a statutory consultee under The Town and Country Planning (Local Planning) (England) Regulations 2012. Anglian Water wants to proactively engage with the local plan process to ensure the plan delivers benefits for residents and visitors to the area, and in doing so protect the environment and water resources. As a purpose-led company, we are committed to seeking positive environmental and social outcomes for our region.
3. Commentary on the GNLP Gypsy & Traveller Sites Focused Consultation
3.1. Anglian Water has contributed to the utilities assessment of the proposed Gypsy and Traveller sites regarding connections to our water supply and water recycling networks and any identified encroachment issues on our assets/network.
3.2. We recognise the wider policy considerations that inform the selection of proposed sites within this consultation. The ability to connect to our networks where sites are adjacent to larger settlements that are serviced by a water recycling centre (WRC) means there are more sustainable and resilient options to treating wastewater arising from Gypsy and Traveller sites. Many of the sites are in rural locations or not closely related to our WRC catchments and therefore are likely to be reliant on non-mains sewerage solutions such as private package treatment plans. A joint advice note by Anglian Water and the Environment Agency in relation to non-mains sewerage options can be found on our website1.
1 https://www.anglianwater.co.uk/contentassets/ff314e5a2ec1452387d7aa04f6519c33/2020-11-10-aw-ea-non-mains-sewerage-advice-note---final.pdf
09.03.2023
2
POLICY GNLP5004 LAND OFF BUXTON ROAD, EASTGATE, CAWSTON
3.3. Anglian Water notes the site is located close to existing development within the settlement, and therefore it is within a reasonable distance to connect to our water supply and water recycling networks.
POLICY GNLP5005 LAND AT STRAYGROUND LANE WYMONDHAM RECYCLING CENTRE, WYMONDHAM
3.4. As referenced as part of the initial assessment, this site is within reasonable proximity to connect to our water supply network, but it is located outside the Wymondham water recycling catchment.
POLICY GNLP5009 LAND OFF HOCKERING LANE, BAWBURGH
3.5. Anglian Water notes the site is located close to existing development within the settlement, and within a reasonable distance to connect to our water supply and water recycling networks.
POLICY GNLP5014 A47 NORTH BURLINGHAM JUNCTION
3.6. The site is located within reasonable proximity to connect to our water supply network, but due to its rural location, it is not within reasonable distance of our water recycling network catchments.
3.7. The A47 road improvement scheme will require the diversion of our assets at this location, and this should be a consideration for future connections.
POLICY GNLP5019 WOODLAND STABLE, SHORTTHORN ROAD, STRATTON STRAWLESS
3.8. The site is located within reasonable proximity to connect to our water supply network, and is adjacent to the Aylsham water recycling catchment, although this part of the network operates as a vacuum sewer system which can take up to 24 months for a connection due to the requirements to assess the capacity of the network. We would suggest that any policy should include a requirement for early engagement with Anglian Water regarding connection to our water recycling network.
POLICY GNLP5020 ROMANY MEADOW, THE TURNPIKE, CARLETON RODE
3.9. The site is located within reasonable proximity to connect to our water supply network, but due to its rural location, it is not within reasonable distance of our water recycling network catchments.
POLICY GNLP5021 LAND OFF HOLT ROAD, HORSFORD
3.10. The site is located within reasonable proximity to connect to our water supply network, but due to its rural location, it is not within reasonable distance of our water recycling network catchments.
3.11. There is a mains water pipe to the northern boundary of the site. We will require sufficient stand-off distances around the water main or diversion at the developers' cost and to the satisfaction of Anglian Water. Further information on the location of our assets can be obtained via utilities.digdat.co.uk
09.03.2023
3
POLICY GNLP5022 LAND OFF REEPHAM ROAD, THE OAKS, FOULSHAM
3.12. The site is located within reasonable proximity to connect to our water supply network, but due to its rural location, it is not within reasonable distance of our water recycling network catchments.
POLICY GNLP5023 LAND OFF STRAYGROUND LANE, WYMONDHAM
3.13. The site is located within reasonable proximity to connect to our water supply network, but due to its rural location, it is not within reasonable distance of our water recycling network catchments.
POLICY GNLP5024 UPGATE STREET, CARLETON RODE
3.14. This site does not appear to be in close proximity to a water supply connection or our water recycling network. As the neighbouring site is occupied and was granted planning permission in 2010, there is an assumption that a water supply is available and sewerage treatment is confirmed as a package treatment plant through the documents submitted with the planning application.
Reasonable Alternative
POLICY GNLP5013 KETTERINGHAM DEPOT LAND WEST OF STATION LANE, KETTERINGHAM
3.15. As a reasonable alternative site, Anglian Water notes that the site is located within reasonable proximity to connect to our water supply network, but it is not within reasonable distance of our water recycling network catchments.
Unreasonable Alternatives
VCHAP SITE 1 AND SITE 2, MIDDLE ROAD, DENTON
3.16. Anglian Water notes the constraints identified regarding these sites and reasons why they have not been brought forward. In terms of access to our water supply and water recycling networks we can state that these sites are located within reasonable proximity to connect to our water supply network, but due to the rural location of these sites, they are not within reasonable distance to connect to our water recycling network catchments.
4. Conclusion
4.1. Anglian Water has assessed the potential to access our water supply and water recycling networks for the proposed Gypsy and Traveller Sites and identified where there are policy requirements regarding connections to our network or to ensure sufficient measures are in place to protect our assets within or adjacent to the proposed sites.

1. Anglian Water
1.1. Anglian Water is the water and water recycling provider for over 6 million customers in the east of England. Our operational area spans between the Humber and Thames estuaries and includes around a fifth of the English coastline. The region is the driest in the UK and the lowest lying, with a quarter of our area below sea level. This makes it particularly vulnerable to the impacts of climate change including heightened risks of both drought and flooding, including inundation by the sea.
1.2. Anglian Water has amended its Articles of Association to legally enshrine public interest within the constitutional make up of our business – this is our pledge to deliver wider benefits to society, above and beyond the provision of clean, fresh drinking water and effective treatment of used water. Our Purpose is to bring environmental and social prosperity to the region we serve through our commitment to Love Every Drop.
2. Anglian Water and Local Plans 2.1. Anglian Water is is the statutory water and sewerage undertaker for the Greater Norwich Local Plan (GNLP) area and a statutory consultee under The Town and Country Planning (Local Planning) (England) Regulations 2012. Anglian Water wants to proactively engage with the local plan process to ensure the plan delivers benefits for residents and visitors to the area, and in doing so protect the environment and water resources. As a purpose-led company, we are committed to seeking positive environmental and social outcomes for our region.
3. Commentary on the GNLP Gypsy & Traveller Sites Focused Consultation
3.1. Anglian Water has contributed to the utilities assessment of the proposed Gypsy and Traveller sites regarding connections to our water supply and water recycling networks and any identified encroachment issues on our assets/network.
3.2. We recognise the wider policy considerations that inform the selection of proposed sites within this consultation. The ability to connect to our networks where sites are adjacent to larger settlements that are serviced by a water recycling centre (WRC) means there are more sustainable and resilient options to treating wastewater arising from Gypsy and Traveller sites. Many of the sites are in rural locations or not closely related to our WRC catchments and therefore are likely to be reliant on non-mains sewerage solutions such as private package treatment plans. A joint advice note by Anglian Water and the Environment Agency in relation to non-mains sewerage options can be found on our website1.
1 https://www.anglianwater.co.uk/contentassets/ff314e5a2ec1452387d7aa04f6519c33/2020-11-10-aw-ea-non-mains-sewerage-advice-note---final.pdf
09.03.2023
2
POLICY GNLP5004 LAND OFF BUXTON ROAD, EASTGATE, CAWSTON
3.3. Anglian Water notes the site is located close to existing development within the settlement, and therefore it is within a reasonable distance to connect to our water supply and water recycling networks.
POLICY GNLP5005 LAND AT STRAYGROUND LANE WYMONDHAM RECYCLING CENTRE, WYMONDHAM
3.4. As referenced as part of the initial assessment, this site is within reasonable proximity to connect to our water supply network, but it is located outside the Wymondham water recycling catchment.
POLICY GNLP5009 LAND OFF HOCKERING LANE, BAWBURGH
3.5. Anglian Water notes the site is located close to existing development within the settlement, and within a reasonable distance to connect to our water supply and water recycling networks.
POLICY GNLP5014 A47 NORTH BURLINGHAM JUNCTION
3.6. The site is located within reasonable proximity to connect to our water supply network, but due to its rural location, it is not within reasonable distance of our water recycling network catchments.
3.7. The A47 road improvement scheme will require the diversion of our assets at this location, and this should be a consideration for future connections.
POLICY GNLP5019 WOODLAND STABLE, SHORTTHORN ROAD, STRATTON STRAWLESS
3.8. The site is located within reasonable proximity to connect to our water supply network, and is adjacent to the Aylsham water recycling catchment, although this part of the network operates as a vacuum sewer system which can take up to 24 months for a connection due to the requirements to assess the capacity of the network. We would suggest that any policy should include a requirement for early engagement with Anglian Water regarding connection to our water recycling network.
POLICY GNLP5020 ROMANY MEADOW, THE TURNPIKE, CARLETON RODE
3.9. The site is located within reasonable proximity to connect to our water supply network, but due to its rural location, it is not within reasonable distance of our water recycling network catchments.
POLICY GNLP5021 LAND OFF HOLT ROAD, HORSFORD
3.10. The site is located within reasonable proximity to connect to our water supply network, but due to its rural location, it is not within reasonable distance of our water recycling network catchments.
3.11. There is a mains water pipe to the northern boundary of the site. We will require sufficient stand-off distances around the water main or diversion at the developers' cost and to the satisfaction of Anglian Water. Further information on the location of our assets can be obtained via utilities.digdat.co.uk
09.03.2023
3
POLICY GNLP5022 LAND OFF REEPHAM ROAD, THE OAKS, FOULSHAM
3.12. The site is located within reasonable proximity to connect to our water supply network, but due to its rural location, it is not within reasonable distance of our water recycling network catchments.
POLICY GNLP5023 LAND OFF STRAYGROUND LANE, WYMONDHAM
3.13. The site is located within reasonable proximity to connect to our water supply network, but due to its rural location, it is not within reasonable distance of our water recycling network catchments.
POLICY GNLP5024 UPGATE STREET, CARLETON RODE
3.14. This site does not appear to be in close proximity to a water supply connection or our water recycling network. As the neighbouring site is occupied and was granted planning permission in 2010, there is an assumption that a water supply is available and sewerage treatment is confirmed as a package treatment plant through the documents submitted with the planning application.
Reasonable Alternative
POLICY GNLP5013 KETTERINGHAM DEPOT LAND WEST OF STATION LANE, KETTERINGHAM
3.15. As a reasonable alternative site, Anglian Water notes that the site is located within reasonable proximity to connect to our water supply network, but it is not within reasonable distance of our water recycling network catchments.
Unreasonable Alternatives
VCHAP SITE 1 AND SITE 2, MIDDLE ROAD, DENTON
3.16. Anglian Water notes the constraints identified regarding these sites and reasons why they have not been brought forward. In terms of access to our water supply and water recycling networks we can state that these sites are located within reasonable proximity to connect to our water supply network, but due to the rural location of these sites, they are not within reasonable distance to connect to our water recycling network catchments.
4. Conclusion
4.1. Anglian Water has assessed the potential to access our water supply and water recycling networks for the proposed Gypsy and Traveller Sites and identified where there are policy requirements regarding connections to our network or to ensure sufficient measures are in place to protect our assets within or adjacent to the proposed sites.

I support, in principle. Everyone needs, and should have, a place to live. Gypsies and Travellers wish to move about and we are a poor society if we can't accommodate and enable that.
But I do think their sites need proper infrastructure – e.g. water, rubbish bin emptying etc.

SUMMARY
Whilst we consider many aspects of the plan to be sound, we have identified issues
with some of the policies and site allocations which do compromise the overall
soundness of the plan.
Under paragraph 35 of the NPPF some aspects of this Plan are unsound as they
have not been positively prepared, are not justified, effective, or consistent with
national policy. We have identified below some of the key areas where we find the
Plan unsound and what measures are needed to make the Plan sound. In summary
we highlight the following issues
1. Recommended changes to policy wording
We are pleased to see the site assessments and sustainability appraisal for the
allocations. Although these are not full heritage impact assessments, these
assessments do make some helpful recommendations for the sites.
However, these recommendations are not always reflected in the policy.
As currently drafted, there is sometimes either a lack of criteria or insufficient
detail within the site-specific policies for the conservation and enhancement of
the historic environment. The NPPF (para 16d) makes it clear that Plans should
contain policies that are clearly written and unambiguous, so it is evident how a
decision maker should react development proposals. Further advice on the content of
policies is given in the PPG at Paragraph: 002 Reference ID: 61-002-20190315
Revision date: 15 03 2019. It states that, ‘Where sites are proposed for allocation,
sufficient detail should be given to provide clarity to developers, local communities
and other interested parties about the nature and scale of development’.
We have therefore suggested a number of relatively minor changes to the policies to
incorporate these recommendations and address some of our concerns.
2. Heritage Impact Assessment of Bawburgh Site
The Bawburgh Site is perhaps most sensitive in heritage terms. There are several
designated heritage assets nearby including the Conservation Area, listed buildings
and scheduled monuments. Indeed, the Site Assessment states that a Heritage
Impact Assessment (HIA) may be required. We concur with this.
Paragraph 31 and 192 of the NPPF requires a proportionate evidence base for Plans
and we consider that an HIA for this site would help to ensure a robust evidence
base for the Local Plan.
Therefore, we recommend that a proportionate Heritage Impact Assessment is
undertaken now to inform the suitability of the site per se, assess the impact, identify
any mitigation and enhancement required and inform any changes to policy wording.
We would remind you that paragraph 32 of the NPPF makes it clear that significant
adverse impacts should be avoided wherever possible and alternative options
pursued. Only where these impacts are unavoidable should suitable mitigation
measures be proposed. Further detail is given in the attached table.
Where a potential impact is identified, wording should be included in the policy and
supporting text to this effect. We suggest the inclusion of additional bullet point in the
site allocation. Ideally, the bullet point should mention the specific asset(s), the policy
requirement (see wording in appendix) and any potential mitigation required.
Closing comments
We have suggested a series of other changes to the Plan. Many of these changes
suggested do not go to the heart of the Plan’s soundness, but instead are intended to
improve upon it. We believe that these comments can be addressed by changes to
wording in the plan.
In preparation of the local plan, we encourage you to draw on the knowledge of local
conservation officers, the county archaeologist and local heritage groups.
Historic England, Brooklands, 24 Brooklands Avenue, Cambridge CB2 8BU
Telephone 01223 58 2749 HistoricEngland.org.uk
Please note that Historic England operates an access to information policy.
Correspondence or information which you send us may therefore become publicly available.
Please note that absence of a comment on a policy, allocation or document in this
letter does not mean that Historic England is content that the policy, allocation or
document is devoid of historic environment issues. We should like to stress that this
response is based on the information provided by the Council in its consultation. To
avoid any doubt, this does not affect our obligation to provide further advice and,
potentially, object to specific proposals, which may subsequently arise as a result of
this plan, where we consider that these would have an adverse effect upon the
historic environment.


GNLP5004
Land off Buxton Road, Eastgate, Cawston
The policy states that an archaeological assessment will be required prior to development which is broadly welcomed. The SA recommends that the policy should make it clear whether these should be desk based of field studies. Moreover, in our view, some assessment is needed to inform any planning application. We therefore advise that the criterion should be amended to read, ‘Planning applications should be supported by archaeological assessment including the results of field evaluation where appropriate.’
The SA also recommends that the landscaping should be species appropriate to the local area.
Amend policy re archaeological assessment to read ‘Planning applications should be supported by archaeological assessment including the results of field evaluation where appropriate.’ And make clear if desk based or field based appropriate.
Amend policy to state that ‘landscaping should be species appropriate to the local area.’

GNLP5005
Strayground Lane, Wymondham Recycling Centre
No comments

GNLP5009 Hockering Lane, Bawburgh

Whilst there are no designated heritage assets within the site, the Bawburgh Conservation Area lies to the west of the site but is separated by a block of development. There are listed buildings and scheduled monuments to the north west of the site across the valley. The development has the potential to impact the significance of these heritage assets via a change in their settings.
The Site assessment suggests the preparation of a Heritage Impact Assessment. The Sustainability Appraisal identifies negative impact.
Given this is one of the more sensitive sites in heritage terms, an HIA should be prepared now to inform the suitability of the site per se and the policy wording.
The policy states that an archaeological assessment will be required prior to development. As with the Cawston site it would helpful for the policy to state if the assessment should be desk based or field based. Moreover, in our view, some assessment is needed to inform any planning application. We therefore advise that the criterion should be amended to read, ‘Planning applications should be supported by archaeological assessment including the results of field evaluation where appropriate.’
The SA recommends that the policy should protect or where possible enhance the trees and hedgerow surrounding the site, which would be likely to help conserve the landscape character and historic settings of nearby heritage assets in Bawburgh by ensuring the site is appropriately screened. This should be included in the policy.
We recommend an HIA is prepared now prior to inform the suitability of the site and policy wording.
Amend policy re archaeological assessment to read ‘Planning applications should be supported by archaeological assessment including the results of field evaluation where appropriate.’ And make clear if desk based or field based appropriate.
Add criterion to read ‘Protect and enhance the trees and hedgerows surrounding the site to conserve the landscape character and historic settings of nearby heritage assets in Bawburgh by ensuring the site is appropriately screened’.

GNLP5014
A47 North Burlingham Junction
We welcome bullet point 3 in relation to landscaping to protect views of non-designated heritage assets nearby.

GNLP5019 Woodland Stable, Shortthorn Road, Stratton Strawless
No comments

GNLP5020 Romany Meadow, The Turnpike, Carleton Rode
Whilst there are no designated heritage assets within the site, there are several grade II listed buildings nearby including The Ashes to the east and a cluster of grade II properties to the northwest. However, the site is quite well contained and intervening landscaping should limit the impact on the historic environment.
We welcome bullet point 4 in relation to landscaping to protect views of nearby listed buildings.

GNLP5021 The Old Produce Shop, Holt Road, Horsford
No comments

GNLP5022 The Oaks, Foulsham
This is an extension of an existing site. Whilst there are no designated heritage assets within the site, the grade II* church of St Andrew lies to the south east of the site. There are three grade II listed buildings close by including Manor Farm House to the west, Old Hall to the East and Old Hall Farmhouse to the north east of the site. However, the site is well screened and there is intervening off- site vegetation. Therefore, we consider any impact on designated heritage assets would be minimal.
We welcome bullet point 4 in relation to landscaping to protect views of nearby listed buildings.

GNLP5023 Strayground Lane, Wymondham
The SA states that the policy could be further improved by detailed requirements to consider landscaping measures to reduce potential for adverse effects on the surrounding landscape character
Add policy criterion to read
‘Landscaping measures to reduce potential for adverse effects on the surrounding landscape character’

GNLP5024 Upgate Street, Carleton Rode
Whilst there are no designated heritage assets within the site, there are two grade II listed buildings to the north of the site and the New Buckenham Conservation Area to the west of the site. The site assessment states that Bunns Bank Linear Earthwork, which elsewhere in its course is scheduled, is adjacent to the site and should be taken into consideration. This requirement should be included in the policy wording of the Plan. We suggest an additional bullet point to the policy criteria.
However, overall the site is well screened and there is intervening off- site vegetation. Therefore, we consider any impact on designated heritage would be minimal.
Amend policy wording to add bullet point to read:
‘Protect the adjacent Bunns Bank Linear Earthwork.‘

Reasonable Alternative Site Policy GNLP5013 Ketteringham Depot land west of Station Lane, Ketteringham
Whilst there are no designated heritage assets within the site boundary, there are two round barrows (scheduled monuments) to the south of the site and several grade II listed buildings nearby. However, these are all over 500 metres from the site. Given the distance and intervening vegetation, we consider there would be little impact on designated heritage.

I would like to express my support for the 12 sites being considered at present.
These sites are needed, and being limited to 53 is in stark contrast to the thousands of homes built and planned for the greater norwich area.
As an example, there is a caravan storage site north of Shortthorn road in Stratton Strawless taking over a hundred caravans, so 4 pitches will have minimal impact.
Wymondham has seen huge numbers of houses built, with more planned, so 10 sites could easily be accommodated.
Please accept my support for these 12 sites.

Objection to the whole proposal.

Item 1. Issues ‐ Encroachment on the boundary fence, interference with sensitive equipment, space for inspection and maintenance of the railway infrastructure.
Reasons/Mitigations:
The developer / designer must ensure that the development line is set back from the Network Rail fence line to achieve sufficient gap / space to inspect and maintain Network Rail fence line and provide an access for inspection and maintenance of the proposed development or other assets in the future without imposing any risks to the operational railway. This would normally be 2‐5m from the boundary fence depending on the adjacent NR assets or boundary fence.
Item 2. Issues ‐ Stability of railway infrastructure and potential impact on the services.
Reasons/Mitigations:
Existing railway infrastructures including embankment should not be loaded with additional surcharge from the proposed development unless the agreement is reached with Network Rail. Increased surcharge on railway embankment imports a risk of instability of the ground which can cause the settlement on Network Rail infrastructure (Overhead Line Equipment / gantries, track, embankment etc.).
Item 3. Issues ‐ Potential buried services crossing under the railway tracks. Some of the services may be owned by Network Rail or Statutory Utilities that may have entered into a contract with Network Rail.
Reasons/Mitigations:
The developer is responsible for a detailed services survey to locate the position, type of services, including buried services, in the vicinity of railway and development site. Any utility services identified shall be brought to the attention of Senior Asset Protection Engineer (SAPE) in Network Rail if they belong to railway assets. The SAPE will ascertain and specify what measures, including possible re‐location and cost, along with any other asset protection measures shall be implemented by the developer.
Item 4. Issues ‐ Proximity of the development to the Network Rail infrastructure and boundary fence and adequate space for future maintenance of the development.
Reasons/Mitigations:
The developer must ensure any future maintenance does not import the risks to the operational railway. The applicant must ensure that the construction and subsequent maintenance of their development can be carried out without adversely affecting the safety of operational railway.
Item 5. Issues ‐ Collapse of lifting equipment adjacent to the boundary fence/line.
Reasons/Mitigations:
Operation of mobile cranes should comply with CPA Good Practice Guide ‘Requirements for Mobile Cranes Alongside Railways Controlled by Network Rail’. Operation of Tower Crane should also comply with CPA Good Practice Guide ‘Requirements for Tower Cranes Alongside Railways Controlled by Network Rail’. Operation of Piling Rig should comply with Network Rail standard ‘NR‐L3‐INI‐CP0063 ‐ Piling adjacent to the running line’. Collapse radius of the cranes should not fall within 4m from the railway boundary unless possession and isolation on NR lines have been arranged or agreed with Network Rail.
Item 6. Issues ‐ Collapse of temporary structure near the railway boundary and infrastructure.
Reasons/Mitigations:
Any temporary structures which are to be constructed adjacent to the railway boundary fence (if required) must be erected in such a manner that at no time will any item fall within 3 metres from the live OHLE and running rail or other live assets. Suitable protection on temporary works (for example: Protective netting around scaffold) must be installed.
Item 7. Issues ‐ Piling adjacent to the railway infrastructure if any. Issues with ground movement affecting the track geometry and surrounding ground and structure stability.
Reasons/Mitigations:
The developer must ensure that any piling work near or adjacent to the railway does not cause an operational hazard to Network Rail’s infrastructure. Impact/Driven piling scheme for a development near or adjacent to Network Rail’s operational infrastructure needs to be avoided, due to the risk of a major track fault occurring. No vibro‐compaction/displacement piling plant shall be used in development.
Item 8. Issues ‐ Trespasses and unauthorised access through an insecure or damaged boundary fence.
Reasons/Mitigations:
Where required, the developer should provide (at their own expense) and thereafter maintain a substantial, trespass proof fence along the development side of the existing boundary fence, to a minimum height of 1.8 metres. Network Rail’s existing fencing / wall must not be removed until it is agreed with Network Rail.
Item 9. Issues ‐ Interference with the Train Drivers’ vision from artificial lighting and human factor effects from glare.
Reasons/Mitigations:
Any lighting associated with the development (including vehicle lights) must not interfere with the sighting of signalling apparatus and/or train drivers’ vision on approaching trains. The location and colour of lights must not give rise to the potential for confusion with the signalling arrangements on the railway. The developers should obtain Network Rail’s Asset Protection Engineer’s approval of their detailed proposals regarding lighting.
Item 10. Issues ‐ Errant vehicle onto the railway land.
Reasons/Mitigations:
If there is hard standing area / parking of vehicles area near the property boundary with the operational railway, Network Rail would recommend the installation of vehicle incursion barrier or structure designed for vehicular impact to prevent vehicles accidentally driving or rolling onto the railway or damaging the railway lineside fencing.
Item 11. Issues ‐ Potential impact on the adjacent railway infrastructure from the construction activities.
Reasons/Mitigations:
The applicant shall provide all construction methodologies relating to works that may import risks onto the operational railway and potential disruption to railway services, the assets and the infrastructure for acceptance prior to commencing the works. All works must also be risk assessed to avoid disruptions to the operational railway.
Item 12. Issues ‐ Structural stability and movement of Network Rail Assets.
Reasons/Mitigations:
Network Rail’s infrastructures should be monitored for movement, settlement, cant, twist, vibration etc if there are risks from the proposed development (if there the proposed development import these risks in the operational railway) to mitigate the risk of adverse impact to the operational railway in accordance with Network Rail standard ‘NR/L2/CIV/177 ‐ Monitoring track over or adjacent to building or civil engineering works’.
Item 13. Issues ‐ Invasive or crawling plants near the railway.
Reasons/Mitigations:
The developer must ensure that the locations and extent of invasive plant (if any, for example: Japanese Knotweed) are identified and treated in accordance with the current code of practice and regulations if exists on site. Any asbestos identified on site should be dealt in accordance with current standard, Health and Safety Guideline and regulations by the developer.
Item 14. Issues ‐ Interference with the Train Drivers’ vision from sunlight and human factor effects from glare.
Reasons/Mitigations:
Glint and Sunlight glare assessment should be carried out (if there is a risk) to demonstrate the proposed development does not import risk of glare to the train drivers which can obstruct in the visibility of the signals.
Item 15. Issues ‐ Effects due to electromagnetic compatibility on the users and the development located within proximity of a high voltage overhead electrification lines. Any Outside Party projects that will be within 20m and/or any transmitter within 100m of the operational railway will be required to undertake an Electromagnetic Compatibility assessment to be carried out in accordance with Network Rail standards ‘NR/L1/RSE/30040 & ‘NR/L1/RSE/30041’ and NR/L2/TEL/30066’
Reasons/Mitigations:
The developer will be required to undertake a full Electro Magnetic Interference (EMC) risk assessment on the impact the project will have upon NR.
Item 16. Issues - Risk of electrocution and EMC interference to human health due to 25kV live OHLE on railway:
Reasons/Mitigations:
• Electrocution Clearance - within 3m of the overhead cable. Distance within which any works will require the overhead cable to be isolated.
• Electromagnetic interference – within 5.2m. Distance within which the effect on human health should be considered.
• Dewirement zone – within 5.2m. Distance within which the overhead cable could reach in the event of a failure.
• Electromagnetic compatibility – within 7m. Distance within which the affect of the building on the cable function needs to be considered in the design.
Item 17. Issues ‐ Environmental pollution (Dust, noise etc.) on operational railway.
Reasons/Mitigations:
Contractors are expected to use the 'best practical means' for controlling pollution and environmental nuisance complying all current standards and regulations. The design and construction methodologies should consider mitigation measures to minimise the generation of airborne dust, noise and vibration in regard to the operational railway.
Item 18. Issues ‐ Tree species alongside the railway boundary.
Reasons/Mitigations:
Contractors are expected to use Network Rail recommended tree species only if required alongside the railway boundary. List of recommended tree species can be made available when requested.
Item 19. Issues ‐ Disruption of access to operational railway.
Reasons/Mitigations:
If there are any access points / gates to the railway, it’s contractor’s responsibility to maintain 24/7 unobstructed access to the railway for maintenance purposes.
Item 20. Issues ‐ Flying objects on operational railway from the playground if any adjacent to the operational railway.
Reasons/Mitigations:
If there are playgrounds next to the operational railway, the developer shall consider a barrier / fence to hold the objects (for example: balls).
Item 21. Issues ‐ There is a risk of obstruction to the visibilities of railway signals due to the development, railway alignment is in a curve.
Reasons/Mitigations:
Project shall engage signal sighting chair and carry out full signal sighting assessment to confirm the railway signals are visible to the train drivers.
Item 22. Issues ‐ Drainage.
Reasons/Mitigations:
Drainage from the shall be taken away from the railway infrastructure. There shall not be any attenuation tank or soakaways within 10-20m from the railway boundary.
Item 23. Issues: Level Crossings:
NR is a statutory consultee when any level crossings are affected in any way by a development. Where a level crossing is in the proximity, the layout for the road design and the access to development should be away from the level crossing; congestion around a level crossing can be problematic. Any increase or change in the nature of usage of any level crossing (whether vehicular, pedestrian, or equestrian) can result in safety issues to the railway and those crossing it. It is not permitted to change the nature or increase the volume of usage at a private level crossing to serve a development. It is NR’s goal to close level crossings wherever reasonably practicable. Level crossings should be replaced with bridges if access over the railway is required.
Item 24. Issues: Bridges
Status of public bridges and their load-bearing capacity must be considered and enhanced at the developer’s expense if needed. It is not generally permitted to change the nature or increase the volume of usage at a private bridge to serve a development. Additional bridges over or under the railway (whether new or as a replacement for an existing bridge and/or level crossing) may be within the scope of NR’s shared value policy and would be expected to vest in a statutory undertaker once completed.
Network Rail strongly recommends the developer contacts the Asset Protection Team AssetProtectionAnglia@networkrail.co.uk prior to any works commencing on site, and also to agree an Asset Protection Agreement with us to enable approval of detailed works. More information can also be obtained from our website https://www.networkrail.co.uk/running-the-railway/looking-after-the-railway/asset-protection-and-optimisation/