Sustainable development in the Broads

Policy PODM1: Major Development in the Broads

  1. For the purposes of this policy, ‘major development’ is defined in this Local Plan as development which has the potential to have a significant adverse impact on the Broads, its purposes and its special qualities due to the development’s nature, scale and setting. ‘Major development’ may include the development covered by the definition set out in the NPPF but is not restricted to that.
  2. Applications for major development will not be permitted other than in exceptional circumstances and where applicants can demonstrate that the development is in the public interest and that public interest outweighs the purposes of the Broads.
  3. Proposals for major development will need to demonstrate:
    1. the need for the development, including in terms of any national considerations;
    2. the impact of permitting or refusing the development upon the local economy and local communities and the extent to which it will provide a benefit to the Broads and wider area;
    3. the cost of and scope for locating the development elsewhere outside the Broads, or meeting the need for it in some other way, and a justified explanation of why these options have been discounted;
    4. that there are no likely significant adverse effects on proposed or current Habitat Sites for nature conservation both within their boundaries and in areas that ecologically support the conservation objectives of the site. Project Level Habitats Regulation Assessments may be needed to assess implications on Habitat Sites. Measures to mitigate for the effects of new development may be required;
    5. any detrimental effect on the natural and historic environment, the landscape, and recreational opportunities, taking into account the special qualities of the Broads, and the extent to which any such effect could be moderated (through applying the avoidance, mitigation and compensation sequence of tests set out in clause 4 of this policy); and
    6. that the cumulative impact of the development when viewed with other development proposals and types of development is acceptable.
  4. Where the tests of clause 3 have been met, then every effort to avoid significant adverse impacts will be required. Where significant adverse impacts cannot be avoided, appropriate steps must be taken to minimise harm through mitigation measures. Appropriate and practicable compensation will be expected for any unavoidable effects that cannot be mitigated.

Reasoned Justification

The purpose of the planning system is to contribute to the achievement of sustainable patterns of development which support and meet the needs of communities and the local economy whilst protecting the special character and assets of importance to these communities and the wider area.

This balance is of particular importance in those areas that have been designated for their special qualities, such as the National Parks and the Broads. These areas are identified in the NPPF as having the highest status of protection in relation to landscape and scenic beauty and where the conservation of wildlife and cultural heritage are important considerations (2023 NPPF paragraph 176). In respect of 'major development' the NPPF states (2023 NPPF paragraph 177) that the scale and extent of development within the Broads should be limited and planning permission should be refused for such development in these areas other than in exceptional circumstances and where public interest can be demonstrated. This policy seeks to apply this national test and provide local guidance.

Footnote 60 of the 2023 NPPF (that relates to paragraph 177) says that whether a proposal is ‘major development’ is a matter for the decision maker, considering its nature, scale and setting, and whether it could have a significant adverse impact on the purposes for which the Broads has been designated. So, for the purpose of this policy, it is considered to be development of a more than local scale and which could be considered to have potentially significant adverse impacts on the Broads and the delivery of the statutory purposes. The identification of major development will be context specific, and a matter of planning judgement and the following criteria will be considered in the assessment:

  • whether the development is Environmental Impact Assessment (EIA) development;
  • developments that fall within Schedule 2 of the EIA Regulations that after being screened by the Broads Authority, are considered as likely to have significant effects on the environment due to their nature, scale and setting and require an assessment;
  • the NPPF 2023 definition of major development in terms of the classification of planning applications (page 69 of NPPF);
  • developments that require the submission of a Transport Assessment (see POSSROADS);
  • further information to consider as set out in the 2023 NPPF and in particular footnote 60; and
  • the development’s impact on the purposes for which the Broads has been designated and/or the special qualities of the Broads.

The above will be relevant considerations and will be considered as part of the assessment by the Broads Authority as decision maker in accordance with paragraph 177 of the 2023 NPPF.

Major Development will typically be a proposal of a scale, character or nature which extends beyond what is needed locally, meaning it may have benefits/impacts which extend beyond the Broads’ boundary. This could include, for example, a reservoir, energy development, major road or rail scheme, minerals, or waste development, large-scale residential or commercial development, or high voltage electricity transmission scheme. However, it could also include smaller scale development with potential to have significant adverse impacts.

There are other potential major developments that are subject to their own policy in this Local Plan; this major development policy will be of relevance to those schemes.

Due to its status as a protected landscape equivalent to a National Park, there will be limited scope for major development in the Broads area. It is the purpose of this policy to provide a framework for dealing with any such development and to ensure that, in considering any such proposal, the particular characteristics and status of the area is accorded the appropriate significance.

A particular scheme that may come forward that will likely be classed as major development is the A47 and this is subject to its own policy detailing specific considerations due to the nature and location of the potential development. The principles of POSSA47 are consistent with the Major Development policy but provide additional guidance. Another scheme that will likely be classed as major development is the Utilities Site development that makes up part of the East Norwich Regeneration Scheme.

It is noted that some major development schemes that occur in the Broads will not be determined by the Authority.

If development falls within the definition of Major Development, applicants will be required to demonstrate why it is in the public interest and that there are exceptional circumstances which justify it. Any proposals for development treated as ‘major development’ should be accompanied by a written statement of justification for the proposal.

If an alternative location is technically and financially viable, applicants will be expected to pursue that option, even if the location within the Broads is more financially advantageous. Where an alternative location outside the Broads is not being pursued a detailed appraisal of alternative options should be submitted

Reasonable alternative options

Original policy with no amendments.

No policy

Sustainability appraisal summary

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

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

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

C: Amended policy: 5 positives. 0 negatives. 0 ? Overall, positive.

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

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

Why has the alternative option been discounted?

An alternative option is to not have a policy. By having a policy, it brings the important considerations into a policy. Other protected landscapes have a policy that builds upon what is in the NPPF. The amended policy is favoured. The amendments are fairly minor in nature, and most are wording changes to make consistent with the NPPF and regulations.

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Policy PODM2: Embodied Carbon

Reducing embodied carbon content through choice of materials

  1. All development should, where practical and viable, take opportunities to reduce the development’s embodied carbon content, through the careful choice, use and sourcing of materials.
  2. Presumption against demolition

  3. To avoid the wastage of embodied carbon in existing buildings and avoid the creation of new embodied carbon in replacement buildings, there is a presumption in favour of repairing, refurbishing, re-using and re-purposing existing buildings over their demolition where this is the most carbon efficient option and the structure contributes, or can be suitably adapted, to the positive character of the local area.
  4. Proposals that result in the demolition of a building (in whole or a significant part) need to be accompanied by a full justification for the demolition.
  5. For non-listed buildings, demolition will only be acceptable where it is demonstrated to the satisfaction of the local planning authority that:
    1. the building proposed for demolition is in a state of such disrepair that it is not practical or viable to be repaired, refurbished, re-used, or re-purposed; or
    2. repairing, refurbishing, re-using, or re-purposing the building would likely result in similar or higher newly generated embodied carbon than if the building is demolished and a new building is constructed; or
    3. repairing, refurbishing, re-using, or re-purposing the building would create a building with such poor thermal efficiency that on a whole life cycle basis (i.e. embodied carbon and in-use carbon emissions) would mean a lower net carbon solution would arise from demolition and re-build; or
    4. demolition of the building and construction of a new building would, on an exceptional basis, deliver other significant public benefits that outweigh the carbon savings which would arise from the building being repaired, refurbished, re-used, or re-purposed.
    5. If a building is demolished, the Authority would expect as much useful material to be reused in the new scheme as possible.
  6. Major development proposals

  7. A development proposal needs to demonstrate how the design and building materials to be used have been informed by a consideration of embodied carbon, and that reasonable opportunities to minimise embodied carbon have been taken.

Reasoned Justification

A significant proportion of a building’s lifetime carbon is locked into its fabric and systems. Embodied carbon means all the carbon dioxide (and other greenhouse gases) emitted in producing materials so in the case of buildings means all the emissions from the sourcing, construction and transportation of building materials, the construction of the building itself, all the fixtures and fittings inside and the deconstruction and disposal at the end of a building's lifetime.

The key to reducing embodied carbon is reusing existing buildings, reusing the materials from demolished buildings, building for longevity, building using materials with a low embodied carbon, and buying locally produced materials. Many buildings are capable of being repaired and altered to suit new uses. Some buildings may only require minor alterations and others may need to be stripped back to their main structural components. High levels of insulation and new technologies can usually be retrofitted to buildings to achieve high levels of thermal and energy efficiency. The priority should be reusing any existing buildings onsite as this enables carbon emissions to be reduced during the production of materials, construction and demolition of the building.

There are three elements to the policy.

  1. The first refers to the choice of materials used and the carbon content of the materials. Design is an important aspect to consider, and the Broads is a protected landscape. The choice of materials will be a key discussion in any scheme in the Broads.
  2. There is a presumption against demolition. The policy sets out tests for a scheme to address if it involves demolition. If demolition is proved to be required, the Authority would encourage the re-use of materials from the demolished building if this were practicable.
  3. The final part of the policy sets specific requirements for major development. All major development proposals should explicitly set out what opportunities to lower a building’s embodied carbon content have been considered, and which opportunities, if any, are to be taken forward.

The RICS Whole life Carbon assessment for the built environment is recommended as an approach for identifying opportunities to reduce emissions over the course of a building’s lifetime. Whole life carbon assessment (WLCA) for the built environment (

The Construction Material Pyramid produced by the Centre for Industrialised Architecture is also a useful tool understanding the impact of different building materials and calculating the carbon emissions.

Reasonable alternative options

No specific policy

Sustainability appraisal summary

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

A: Preferred Option, 3 positives. 0 negatives. 3 ?

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

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

This is a new policy.

Why have the alternative options been discounted?

Climate change and carbon emissions are significant current issues. On occasion, there are proposals in the Broads for buildings to be demolished. A policy that introduced tests and considerations to fully justify any demolition is favoured.