Validation Checklist 2

Validation Checklist 2

Affordable Housing Statement

The Broads Authority applies the policies of its constituent District Council regarding affordable housing.  The thresholds and percentages of affordable housing required are as set out below and an Affordable Housing Statement will be required when the thresholds are met.

Where a site is split between the Broads and the area of another Local Planning Authority, the site will be considered as a whole and a comprehensive scheme will be required.  If this meets the threshold for affordable housing. Where the relevant thresholds are met, an Affordable Housing Statement will be required.  This will provide information concerning both the affordable housing and any market housing, the mix of units with numbers of habitable rooms and/or bedrooms, or the floor space of habitable areas of residential units, plans showing the location of units and their number of habitable rooms and/or bedrooms, and/or the floor space of the units. If different levels or types of affordability or tenure are proposed for different units this should be clearly and fully explained. Further information on affordable housing can be found in 'Planning Policy Statement 3: Housing' or the 'Delivering Affordable Housing Policy Statement' November 2006.

Air Quality Assessment

There are national standards set for air quality, with Air Quality Objective levels for a range of pollutants.  The Environmental Health Departments of the constituent Districts monitor air pollution levels within their areas and advise where a development proposal would be likely to generate levels of pollution which would cause the objectives' levels to be exceeded. There are few areas in the Broads which are likely to be affected, but details on the areas potentially affected can be obtained through the Broads Authority.

An Air Quality Assessment should be undertaken by a suitably experienced company and submitted in support of the planning application.  This will need to assess the pollution generated by the development, in both construction and operational stages, and the impact of this on the Air Quality Objectives, which are human health based objectives looking at the exposure of the closest receptor to the source of the pollution. Should the assessment demonstrate that as a result of the development that the objective levels would be exceeded, then measures for mitigation will need to be detailed for agreement.

It may be necessary for the applicant to agree to undertake monitoring of the area to monitor the impact of the development both during construction and when in use and for a period of at least 12 months after completion.

Should the levels exceed the objective threshold, the District Council would need to declare an Air Quality Management Area.  This would then require a further detailed assessment of the air quality using continuous monitoring equipment (taking readings every 10 minutes) for at least 12 months and the production of an Air Quality Action Plan.  This would need to be funded by the developer and would be the subject of a S106 Legal Agreement. Further advice is available in 'Planning Policy Statement 23: Planning and Pollution Control'.

Bio-diversity and/or Geo-diversity Survey and Report

The area of the Broads includes international, national and local designations for wildlife value and any proposed development must take account of this.  In addition, change outside those designated areas can affect them as the eco-systems are interlinked.  All applications should also consider opportunities to restore, enhance or create features of biodiversity as these can add to the special qualities of the Broads.

Many species of plant and animal are given legal protection under both national; and European law; this may apply to the habitat and feeding or roosting grounds, as well as to the animals themselves.  In addition, a number of habitats and species are identified as priorities in the UK and Norfolk and Suffolk Biodiversity Action Plans (BAP). The possibility of any such species and habitats must always be considered and where such species are or may be present, a Biodiversity survey and report must be undertaken.

Plans should show any significant wildlife habitats or features and the location of habitats of any species protected under the Wildlife and Countryside Act 1981, Conservation (Natural Habitats etc) Regulations 1994 (as amended 2007) or Protection of Badgers Act 1992. Applications for development in the countryside that will affect sensitive areas must be accompanied by ecological assessments and include proposals for long term maintenance and management. The Broads Authority have produced a more "Broads specific" checklist (word doc) [71kb] which will provide guidance on when an assessment will be required and what this should cover.

The following is an extract covering some of the more common types of development, showing where a biodiversity survey and report will always be needed and the species that should be surveyed for:

Conversion of agricultural building:  bats, barn owls, breeding birds. Minor or householder development within 100m of a pond or waterbody:  great crested newts, water voles, amphibians All bridge structures:  bats, otters, water voles. A full ecological survey of the site may be required to cover all protected species and priority BAP species and also to assess the overall nature conservation value of the site.  This should include an initial ecological assessment of the site, a full ecological assessment including the likely impact of the proposal and mitigation measures, including post-construction monitoring, if required as a result of the initial assessment.  In some cases, enhancement measures which improve habitat connectivity and contribute to the creation of ecological networks will be required. When preparing the ecological assessment, seasonality is very important. The time of year when a survey can be undertaken may vary according to the species.  Details can be found at or contact the Broads Authority for advice.

In appropriate cases, the above information may be required to be included in an Environmental Statement or an Appropriate Assessment under the Conservation (Natural Habitats etc) Regulations 1994.  If you think this may apply to your proposal please contact the Broads Authority for advice. Further detailed guidance on dealing with nature conservation and development is given in PPS9 and its accompanying Good Practice Guide. Further details of accredited ecological consultants can be found at the Institute of Ecologist and Environmental Management or Environmental Data Services

In addition to bio-diversity, the Broads contain a number of sites of significant geo-diversity value. If these sites are lost through inappropriate development they cannot be recreated. Any proposal on or near a site of value for its geo-diversity must be accompanied by a survey. This must include a description of the features on site and an assessment of their value, as well details of the measures to be taken for their protection and any mitigation measures proposed. The scope and degree of the survey will vary according to the particular circumstances of each application. Further detailed guidance given in PPS9 and its accompanying Good Practice Guide.

Daylight/Sunlight Assessment

In circumstances where there is a potential adverse impact upon the current levels of sunlight/daylight enjoyed by adjoining properties or building(s), including associated gardens or amenity space then applications may also need to be accompanied by a daylight/sunlight assessment. Further guidance is provided in, for example, BRE guidelines on daylight assessments 'Site layout planning for daylight and sunlight: a guide to good practice ' (BRE Report 209, 1991). The grant of planning permission does not confer any immunity on those whose works infringe another's property rights, and which might be subject to action under the Rights of Light Act 1959.

Economic Statement

Applications should be accompanied by a supporting statement of any economic growth/regeneration benefits from the proposed development including: details of any new jobs that might be created or supported; the relative floorspace totals for each proposed use; and any community benefits.  Applications should demonstrate how they will contribute to the implementation of the goals of the Regional Economic Strategy, relevant sub—regional objectives and any economic/regeneration strategies.

Environmental Statement

The Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999 require the submission of an Environmental Statement (ES) for all projects listed in Schedule 1 and for some projects listed as Schedule 2 projects in the Regulations. There is a process known as 'screening' for the Broads Authority to give a formal opinion as to whether or not an ES is required.  The Regulations provide a checklist of matters to be considered for inclusion in the Environmental Statement and require the developer to describe the likely significant effects of a development on the environment and to set out the proposed mitigation measures. Please contact the Broads Authority if you think that your proposal may be covered by the Regulations.

Flood Risk Assessment

The requirement for a Flood Risk Assessment (FRA) will depend on which flood risk zone the application site is in and the flood vulnerability of the type of development proposed.  Information on where an FRA will be required is provided by the Environment Agency.

A FRA will always be required for:

all operational development over 1 hectare;
all operational development less than 1 hectare unless in Flood Risk Zone 1;
change of use resulting in development which is defined as 'highly vulnerable' or 'more vulnerable' in Planning Policy Statement 25 unless in Flood Risk Zone 1.

A FRA may be required for:

other changes of use;
non-residential extensions;
householder development.

You should contact the Broads Authority or the Environment Agency to discuss the requirements for your proposal. The objectives of an FRA are to establish the following:

whether a proposed development is likely to be affected by current or future flooding from any source;
whether it will increase flood risk elsewhere;
whether the measures proposed to deal with these effects and risks are appropriate;
whether the site will be safe.

All FRAs should be prepared on a site specific basis and relate to the application site.

Foul Sewage and Drainage Assessment Information

As a wetland environment, the Broads is particularly sensitive to pollution, particularly to the water.  Diffuse pollution, including from sewage treatment, in an increasing problem and the Broads Authority is seeking to reduce reliance on non-mains sewerage systems.  If an application proposes to connect a development to the existing drainage system then details of the existing system should be shown on the application drawing(s).

It should be noted that in most circumstances surface water is not permitted to be connected to the public foul sewers. Where the development involves the disposal of trade waste or the disposal of foul sewage effluent other than to the public sewer, then a fuller foul drainage assessment will be required including details of the method of storage, treatment and disposal. A foul drainage assessment should include a full assessment of the site, its location and suitability for storing, transporting and treating sewage.

Where connection to the mains sewer is not practical, then the foul/non-mains drainage assessment will be required to demonstrate why the development cannot connect to the public mains sewer system and show that the alternative means of disposal are satisfactory. Guidance on what should be included in a non-mains drainage assessment is given in DETR Circular 03/99 and Building Regulations Approved Document Part H and in BS6297.

If the proposed development results in any changes or replacement to the existing system or the creation of a new system, scale plans of the new foul drainage arrangements will also need to be provided. This will include a location plan, cross sections/elevations and specification.  Drainage details that will achieve Building Regulations Approval will be required. If connection to any of the above requires crossing land that is not in the applicant's ownership, other than on a public highway, then notice may need to be served on the owners of that land.

Applications should include details of the disposal of surface water run-off. Where it is proposed to drain this to existing drains the location of those drains should be indicated and where Sustainable Drainage Solutions (SuDS) are proposed there should be sufficient engineering, geotechnical and hydrological information provided to demonstrate the feasibility and suitability of the proposed solution.

Heritage Statement (including historical, archaeological features and Scheduled Ancient Monuments).

The requirement for supporting information will depend upon the sensitivity of the site and the surrounding features.  Supporting information may include plans showing historic features that may exist on or adjacent to the application site including listed buildings and structures, historic parks and gardens, and historic battle fields.

Where the site is in an area identified as of known or potential importance or is close to a Scheduled Ancient Monument a Statement will always be required.  Sites of archaeological potential include all development sites of over 0.5 hectare, other areas that are the subject of major development proposals of significant infrastructure works and all development sites within 100m of a known archaeological site.

The Statement should describe the archaeological content or assess the potential, and detail any measures of investigation, mitigation or protection to be undertaken. For works to Listed Buildings , a written Statement which includes a schedule of works to the listed building(s) and an analysis of the significance of archaeology, history and character of the building/structure, the principles of and justification for the proposed works and their impact on the special character of the listed building or structure, its setting and the setting of adjacent listed buildings may be required.

The Heritage Statement should be prepared by a qualified professional archaeologist.  In the case of barn conversions and changes of use (including demolition) of other traditional buildings, the Statement relating to the above ground structure should be prepared by a qualified professional architectural historian. The scope and degree of detail necessary in the written Statement will vary according to particular circumstances of each application

Norfolk Landscape Archaeology and Suffolk County Council Archaeology Service will advise where additional information is required where it is not submitted with a planning application.

Further guidance on archaeology, the historic environment and planning can be found in Planning Policy Guidance Note 16 'Archaeology and Planning' and Planning Policy Guidance Note 15 'Planning and the Historic Environment'.  Guidance can also be found in the English Heritage publication 'A Charter for English Heritage Advisory Services' and ODPM Circular 08/2005. You should contact the Broads Authority to discuss the requirements for your proposal.

  • Listed Buildings Applications

For listed building consent, applications must be accompanied by a Design and Access Statement. In particular, such a statement should address:
(i)  the special architectural or historic interest of the building;
(ii)  the particular physical features of the building that justify its  designation as a listed building; and
(iii)  the building's setting.

The legislative requirements are set out in regulation 3A of the Planning (Listed Buildings and Conservation Areas) Regulations 1990.

Land Contamination Assessment

Applications will need to be accompanied by a land contamination assessment where there is a likelihood that a previous land-use has produced contamination or pollution which will have affected the site.  A report will always be required where the previous use was commercial (excluding Class A uses under the Use Classes Order) or industrial.

Sufficient information should be provided to determine the existence or otherwise of contamination, its nature and the risks it may pose and whether these can be satisfactorily reduced to an acceptable level.  Where contamination is known or suspected or the proposed use would be particularly vulnerable, the applicant should provide such information with the application as is necessary to determine whether the proposed development can proceed.

Further details on the requirements can be found in Planning Policy Statement 23: Planning and Pollution Control (November 2004).


All applications will be required to be accompanied by a plan showing the position on-site of all trees and hedgerows.  The plan should show their species and size, including the canopy spread, with details of any to be retained together with measures for their protection during the course of development.  It may be appropriate to show these on the mandatory block plan.

The landscaping scheme shall show details including the size and species of any new trees or hedgerows which are to be planted as a part of the development and proposals for their long term maintenance and landscape management.

Lighting Scheme / Light Pollution Assessment

Proposals involving the provision of publicly accessible developments or in the vicinity of residential property or affecting a listed building or a conservation area, or in open countryside or where external lighting would be provided or made necessary by the development, are required to be accompanied by details of external lighting and the proposed hours when the lighting would be switched on.  These details shall include a layout plan with beam orientation and a schedule of the equipment in the design.

Noise Impact Assessment

Application proposals that raise issues of disturbance or are considered to be a noise sensitive development must be supported by a Noise Impact Assessment prepared by a suitably qualified acoustician.  Further guidance is provided in 'Planning Policy Guidance 24: Planning and Noise'. 

Open Space

Plans should show any areas of existing or proposed open space within or adjoining the application site. 'Open space' here includes space falling within the definitions of that term in the Town and Country Planning Act 1990 or Planning Policy Guidance Note 17. 

Parking Provision

Developments which will generate additional vehicular movements to a site must provided details of the additional parking which will be provided to accommodate the extra vehicles. Proposals for holiday or other accommodation will need to demonstrate that adequate parking can be provided. These details could also be shown on a site layout plan.

Photographs and Photo Montages

These provide useful background information and can help to show how developments can be satisfactorily integrated within the street scene. Photographs must be provided if the proposal involves the demolition of an existing building or development affecting a conservation area or a listed building.

Planning Obligations

This will include brief draft heads of terms for a section 106 agreement or unilateral undertaking. Applicants should clarify the LPAs requirements in pre-application discussions and confirm any planning obligations that they agree to provide in brief heads of terms. Further advice is available in Circular 1/97: Planning Obligations. 

Statement of Community Involvement

Major applications or those which are controversial or on sensitive sites or on a significant scale will need to be supported by a statement setting out how the applicant has engaged with the local community at a pre-application stage.  This process should have established local issues and concerns and these should have been addressed in the application.

There are a range of pre-application engagement techniques which can be used, including public exhibitions, public meetings, press releases and public notices.  In the case of major applications, there are considerable benefits to be gained from wider community involvement throughout the application process  As a minimum, for minor applications we recommend that applicants consult immediate neighbours before submitting an application.

Further guidance on Statements of Community Involvement is available in Chapter 7 of 'Creating Local Development Frameworks: A Companion Guide to PPS12' (November 2004).

Structural Survey of the Property

A structural survey will be required for all proposals for the conversion of an existing building, in whatever condition, to an alternative use or for proposals which involve re-building works or demolition. The structural survey will need to be carried out by a competent surveyor and should demonstrate that the building is capable of conversion.

Telecommunications Development – Supplementary Information

Planning applications for mast and antenna development by mobile phone network operators in England must be accompanied by a range of supplementary information including the area of search, details of any consultation undertaken, details of the proposed structure, and technical justification and information about the proposed development.

Planning applications should also be accompanied by a signed declaration that the equipment and installation has been designed to be in full compliance with the requirements of the radio frequency (RF) public exposure guidelines of the International Commission on Non-Ionizing Radiation Protection (ICNIRP). Further guidance on the information that may be required is set out in the Code of Practice on Mobile Network Development (2002).

Transport Assessment

A Transport Assessment (TA) should be submitted as part of any planning application where the proposed development has significant transport implications. The coverage and detail of the TA should reflect the scale of the development and the extent of the transport implications of the proposal. For smaller schemes a Transport Statement (TS) is likely to be sufficient.  The TS should simply outline the transport aspects of the application, while for major proposals, the TA should illustrate accessibility to the site by all modes of transport, and the likely modal split of journeys to and from the site. It should also give details of proposed measures to improve access by public transport, walking and cycling.
A full TA is likely to be required for schemes of over 80 units, whereas schemes of 50 – 80 residential units will require a TS.  Guidance on the level of detail which is required is set out in the Department of Transport Guidance on Transport Assessments and this must be complied with.  The Highways Agency should be consulted in the preparation of any TA/TS document concerning a proposal which may impact on a Trunk Road.

It is not likely that many applications in the Broads Authority area will require a TA or TS, but please contact us to discuss it if you think that your proposal will be covered.  All proposals which involve an alteration to the public highway will need to be accompanied by a formal Road Safety Audit (RSA) in accordance with DfT guidance HD 19/03 which shall be carried out by a suitable experienced safety auditor approved by the Local Highway Authority.

It is not likely that many applications in the Broads Authority area will require a RSA, but please contact us to discuss it if you think that your proposal will be covered.

Green Travel Plan

A Green travel plan should outline the way in which the transport implications of the development are going to be managed in order to ensure the minimum environmental, social and economic impacts.  Further advice is available in 'Using the planning process to secure travel Plans:  Best practice guide' by the ODPM and Department for Transport 2002.  Norfolk County Council also has guidance notes for the submission of travel plans.

Tree Survey / Arboricultural Statement

Where the application involves works that affect any trees within the application site, the species, spread, roots and position of trees should be illustrated accurately on the site plan.  This must indicate any trees which are to be felled or affected by the proposed development.  The location of any trees within adjacent properties that may be affected by the application should also be shown.
A statement in relation to the measures to be adopted during construction works to protect those trees shown to be retained on the submitted drawings may also be necessary.  Details of replacement trees or hedges, including measures for maintenance and after-care should also be included. Further guidance is also provided in BS5837:1991 'a guide for trees in relation to construction'. If the trees are protected by a Tree Preservation Order or are within a Conservation Area formal consent will be needed and the appropriate forms can be obtained from the Broads Authority.

Utilities Statement

An application should indicate how the development connects to existing utility infrastructure systems.  Most new development requires connection to existing utility services, including electricity and gas supplies, telecommunications and water supply, and also needs connection to foul and surface water drainage and disposal.  Two planning issues arise; firstly, whether the existing services and infrastructure have sufficient capacity to accommodate the supply/service demands which would arise from the completed development, and secondly, whether the provision of services on site would give rise to any environmental impacts, for example, excavations in the vicinity of trees or archaeological remains.
For all major applications, information must be submitted to demonstrate that:

(a)  following consultation with the service provider, the availability of utility services has been examined and that the proposals would not result in undue stress on the delivery of those services to the wider community;
(b)  proposals incorporate any utility company requirements for substations, telecommunications equipment or similar structures;
(c)  service routes have been planned to avoid as far as possible the potential for damage to trees and archaeological remains;
(d)  the development impinges on existing infrastructure the provisions for relocating or protecting that infrastructure have been agreed with the service provider.

Where appropriate, all applicants must indicate the likely infrastructure requirements of their proposal and the proposed timing of this in order that the works can be programmed and co-ordinated in accordance with the objectives set out in the Traffic Management Act 2004 in consultation with the Local Highways Authority.

Ventilation/Extraction and Refuse Disposal Details

Details of the position and design of ventilation and extraction equipment, including odour abatement techniques and acoustic noise characteristics, will be required to accompany all applications for the use of premises for purposes within Use Classes A3 (i.e. Restaurants and cafes – use for the sale of food and drink for consumption on the premises), A4 (i.e. Drinking establishments – use as a public house, wine-bar or other drinking establishment), A5 (i.e. Hot food takeaways – use for the sale of hot food for consumption off the premises), B1 (general business) and B2 (general industrial).  This information (excluding odour abatement techniques unless specifically required) will also be required for significant retail, business, industrial or leisure or other similar developments where substantial ventilation or extraction equipment is proposed to be installed.

(Date last reviewed 10/10/2018)