11/00713/F - Borough Council of King's Lynn & West Norfolk

5) Reason The information presented in the Environmental Statement indicates that the
development will generate peak hour HGV movements. Given the concerns expressed
by the Highways Agency over this issue at the Scoping stage of the ES and errors in the
assumptions about traffic flows and distributions throughout the day, the applicant has
failed, at this stage, to demonstrate that the development will not adversely impact upon
the local and trunk road network. The proposal is therefore contrary to national
government guidance in PPG13 'Transport'.
6) Reason The Environmental Statement fails to adequately address the cumulative
landscape and visual impact of the proposed development when considered with other
committed development in the area.
7) Reason The Environmental Statement does not appear to adequately address concerns
expressed at the Scoping stage of the project by Norfolk Wildlife Trust. These concerns
related to the impact of acid deposition upon plant communities on Roydon Common,
which is a Site of Special Scientific Interest and a European-designated Special Area of
Conservation. Unless and until these issues are addressed, the proposal is contrary to
Planning Policy Statement 9 'Biodiversity and Geological Conservation' and to the
provisions of the Nature Conservation (Natural Habitats _c.) Regulations 1994 (as
amended).
8) Reason The Environmental Statement fails to follow the procedures agreed between the
Environment Agency and the Local Planning Authority for assessing flood risk in the
Borough, which is aimed at directing development to areas at lowest risk of flooding.
Consequently, the approach adopted in the ES underestimates the risk of flooding and
fails to follow the hierarchical approach to flood risk management set out in PPS25. As a
result, the development is contrary to central government guidance in PPS25
'Development and Flood Risk' and the associated good practice guide.
9) Reason The Environmental Statement fails to identify that the proposed Energy from
Waste plant has features in common with 'Essential Infrastructure' as described in Annex
D to PPS25. As a result, the ES fails to adequately apply the Sequential Test to site
location that is required before 'Essential Infrastructure' should be considered acceptable
in Flood Zone 3. The Sequential Test that has been carried out is flawed in that it does
not use the approach agreed between the Environment Agency and the Borough Council
and, in addition, is inappropriately constrained as a result of the assumptions made
about the Waste Core Strategy referred to in (3) above.
10) Reason The Environmental Statement fails to adequately address the impact of the
proposed Energy from Waste plant upon the ability of King's Lynn to continue to attract
inward investment in line with its status as a Growth Point. Until this issue is addressed,
the proposal is contrary to criteria (d) and (e) of policy EC10 in PPS4 'Planning for
Sustainable Economic Growth' and could also adversely impact upon Core Strategy
policies CS01 and CS03
11) Reason The Environmental Statement fails to adequately address the impact of the
development during construction and operation upon residential amenity in terms of
noise, odour and dust. Unless and until this issue is addressed, either through the use of
appropriate conditions or by the submission of additional information to quantify the
impacts, the development is contrary to national government guidance in PPG24
'Planning and Noise' and central government policy in PPS23 'Planning and Pollution
Control'.
11/01064/CM Development Control Board
25 July 2011
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