The Applications

The council's agent applied on Thursday 25 November 2004 - during National Tree Week! (Not only is the application wrong, the timing is insensitive.) That was the day when WAG supporters asked questions at the Council's public meeting: the replies did not mention that the planning applications were in already. The two applications are:

• 04/02500/F - Construction of park management building/kiosk, new pedestrian bridge, new steps to bandstand, re-opening of entrance to Redmount Chapel and associated works
• 04/02501/LB - Alterations and repairs to Sevensisters bridge, Broadwalk bridge, re-opening of entrance to Redmount Chapel and repairs to Guannock gates/archway

Neither of the summaries mention the tree clearances. They are included by a "YES" in a box on the back of the form for 04/02500/F and the inclusion of drawing LA/140. Instead, smaller parts like "new steps to bandstand" are mentioned. This obscure wording meant some people weren't sure whether this included the clearances.

The submission timing cut over a week from possible time for public viewing. Also, the planning office will close from 24 December to 3 January, cutting another half a week. Finally, the deadline for comments is 28 December and we know how busy everyone is in the run up to Christmas.

In short, the project is not following the "general policy of candour and openness" required by section 3.13.3 of the national code of practice for planning information.

Site Notices

Some site notices were spotted on 9 or 10 December. Bizarrely, they are pinned to trees by the library and Avenue Road, rather than on the project noticeboards and the buildings to which they apply. Anti-felling notices pinned to trees don't seem to last very long. How long will planning notices last?

Written Comments

Objecting successfully is difficult. Basically, you have to convince the council that approving this plan would contradict their current policy. This section lists some policies you may want to mention.

Fortunately, the current borough local plan, county structure plan and national planning policy guidelines are all supposed to protect the environment, biodiversity, conservation areas, air quality and public amenities, while application 04/2500/F will harm all of those. If you find things which seem to apply to the Walks, please email me and I'll post them here: mjr at dsl.pipex.com

Local Plan

The Borough Council's own Local Plan is available in the town library or the planning department (both maps and written statements, also on sale in the planning department at a price of 15 pounds) and the local plan is available online (added Feb 2005). It includes the following policies which seem relevant:

• Policy SS1: "The Council will conserve the variety of important habitats and encourage habitat creation, to improve biodiversity."
• Guiding Principle 3 is "Conserving Environmental Quality" which includes Policy SS3: "The Council will conserve the quality and character of the borough's countryside and coast and the built environment of its towns and villages."
• Policy SS6: "... Provision will be made for development which meets the health and leisure needs of the local community."
• Policy SS7: "The Council will promote sustainability by conserving the environment, ensuring that development permitted under the plan is well-related to its settlement structure, seeking to make best use of under-used land and promoting effective use of public transport systems, cycling and walking."
• Policy 4/4: "...In considering applications the Council will have special regard to their nature conservation importance and may impose conditions to avoid harmful impacts..." [Tree felling will harm wildlife]
• Policy 4/8: "Development which would be detrimental to the historic landscape characteristics of historic parks and gardens, shown on the Proposals Map, will not be permitted." [The Walks is a listed historic park and felling will destroy the historic character.]
• Policy 4/9: "...Development which would have an adverse effect on their site or setting will not be permitted."
• Policy 4/14: "Development proposals in the vicinity of Conservation Areas should have regard to their impact on the settings of and views into and out of the areas..." [The Walks is a Conservation Area and tree clearance/ replacement will open up views of the football ground stands and Vancouver House.]
• Policy 4/19: "Work affecting Listed Buildings, and development proposals in surrounding area, should preserve the historic character and architectural harmony of the setting to such buildings. Permission will not be granted for projects which adversely affect the setting of Listed Buildings." [Planting avenues in 1750s and 1840s style next to each other will change the historic character of the setting of the Red Mount Chapel.]
• Policy 9/14: "Development likely to result in permanent loss of open space and land with amenity or recreation value like parks, playing fields or allotments, will be resisted." [The hard paths across the recreation ground and the new park centre will permanently reduce the amount of open space. Also, the original lottery bid claimed that tree clearances would "destroy the amenity value of the park."]
• Policies 9/19, 9/20 and 9/21 cover flooding and flood plains. Have the effects of the drainage and waterway works been investigated?
• Policy 9/31 covers noise protection. Simultaneously replacing large numbers of mature trees with little ones will reduce noise protection.

Structure Plan

The County Council has a structure plan for Norfolk, as required by law. Look for policies in the Environment and Sport sections. Ignore the stupid text telling you that you can't print them out - I think GSView on Windows (and Ghostscript and XPDF on GNU/Linux) will print them. There's a printed copy in the town library too.

There is also the Norfolk Biodiversity Action Plan Supplementary Planning Guidance which refers to the structure and local plans.

Planning Policy Guidelines

The Office of the Deputy Prime Minister is responsible for the English planning system. They publish Planning Policy Guidelines (PPG) and the Borough Council should update their policy accordingly. Try PPGs 9, 15, 17 and 21-25.

Sending Comments

Send comments to David Parkin, Planning Officer, Borough Council, King's Court, King's Lynn, PE30 1EX.

GO-East

The applications have been referred to national government. I guessed this was probably because 04/02500/F breaches the local plan and 04/02501/LB concerns listed buildings and an ancient monument, but the Walks project manager tells me both are just referred for involving listed buildings. The local plan is covered by the Office of the Deputy Prime Minister (John Prescott) and listed buildings by the Department of Culture Media and Sport (led by Tessa Jowell).

In practice, this means the applications go to the Government Office for the East of England, known as GO-East for short. They are the local representatives of both departments concerned. It will be handled by their Planning Casework Team and you can send comments by post to L.Caudrey, GO-East, Eastbrook, Shaftesbury Road, Cambridge CB2 1DF.

All comments will be considered, but apparently they do not very often dispute local council opinions! Here's hoping that this one is reviewed extra-carefully.

At the end of the day, why should anyone still object to this?

1. The planning applications still include the excessive felling drawing LA/140, which could be trivially removed if planning permission isn't required (as argued by the Council planning officer).
2. The kiosk design is disliked by English Heritage, who give the Walks its grade II listing and also the building listings. They are the experts in this case.
3. The kiosk position does not follow police security advice and the wood roof seems like an invitation to vandals. It also uses a busy path and cycleway as an access road, while building in a no-building local plan zone.