Planning – Application Comments

Consultation Date: Mon 20 Oct 2025

Comment Date: Fri 17 Jul 2026

This is a matter of potential impacts on protected habitats, and I defer to and support the comments of the Senior Ecologist.

Comment Date: Fri 21 Nov 2025

Thank you for consulting Ecology on p.a. 25/01492/CHSR17|Application under the Habitats Regulations 2017 arising from Application for a Lawful Development Certificate for the proposed change of use of agricultural building to small Hotel (C1) (Schedule 2, Part 3, Class R) under LPA reference: 23/00566/PACU6 (confirmed on appeal)|Land And Building E566533 N336853 At 74 South Beach Road Heacham Norfolk.

The following documents have been submitted in support of this application and are relevant to these comments:

' Supporting Evidence for Appropriate Assessment (sHRA) (Wild Frontier Ecology, May 2023)

There is not currently sufficient information to conclude a no Likely Significant Effect on Habitats Sites. The sHRA does come to this conclusion but the report is out of date (2.5 years old) and does not reflect statutory consultee requests for further information. Statutory consultee Natural England have requested further information on the following:
1) Recreational Disturbance (In-combination Impacts)
2) Recreational Disturbance (Alone Impacts)
3) Water Quality Impacts (Foul & surface water)

I agree that further information on these points is required and provide further detail on the issues below.

Hydrology ' foul water

Based on the information provided in the current consultation, there still appears to be a lack of certainty on how the foul water will be treated and disposed of. The sHRA states:

`the installation of a package treatment plant at the site which would discharge treated water into the ground is proposed. The discharged water would contain only trace amounts of nutrients; a permit from the Environment Agency is currently being applied for to enable this sewage solution. The Habitats sites within Norfolk for which development proposals must demonstrate maintenance of 'nutrient neutrality' are the River Wensum SAC and The Broads SAC. However, as the proposal at Beach Farm is well separated from the catchments of these designated sites, there is considered to be no risk of an adverse effect on the integrity of the relevant Habitats site. Furthermore, the proposed development involves conversion of an existing building, so no discernible changes to surface water flows are expected`

The sHRA focuses on the impact of foul water in regards to the Nutrient Neutrality Catchment of the River Wensum SAC. However, it fails to assess the impact of changes in water quality on The Wash and North Norfolk Coast Special Area of Conservation (SAC) and The Wash Special Protection Area (SPA). These sites are less than 500m from the site boundary and include designated features that are sensitive to changes in water quality.

New foul water sources can increase the levels of nitrogen and phosphate within coastal habitats. Eutrophication, acidification and toxic pollution of habitats drive declines in the presence, abundance and health of species and habitat assemblages. Some of the Qualifying Species Features that are not known to be specifically sensitive to changes in water quality are still reliant on habitats that are. Any changes to water quality could therefore be an indirect impact on such species and a direct impact to sensitive habitats.

According to the sHRA the foul water treatment system which the Applicant is proposing to install is the BioRock® 5000. Natural England notes that this represents a change from the information provided in the original sHRA (dated February 2023) where it was proposed that the PTP would discharge to surface water. The sHRA (May 2023) claims that this system would lead only to trace inputs of nutrients being discharged to ground and impacts are scoped out on that basis. However, the Treatment Performance Results certificate is provided in Appendix 3 of the sHRA and that performance certificate does not include any values for phosphate and nitrogen. The quantity of these elements being discharged from this system is therefore not known and the statement that only traces will be discharged is not evidenced.
An application for a permit to discharge to ground was being processed by the Environment Agency according to the sHRA dated 2023. Evidence of this permit is not provided within the application. If the EA permit is not likely to be granted, further information on the revised foul water solution should be provided to facilitate an assessment of potential impacts on Habitats Sites.

Recreation - in combination

A GIRAMS tariff of £495.81 was paid on 20/03/2023 under p.a. 23/00566/PACU6 when the tariff was set at 185.93. The application was calculated per bedspace at that time i.e. (185.93/6)*16. The tariff must be paid at the time of consideration. The tariff is currently £304.17 and the fee for this application is calculated as £811.12 ((304.17/6)*16). £315.31 must be paid to fully offset the proposed development.

Recreation alone -

The sHRA concludes that there will not be a significant effect from recreation from the proposed development alone. However, Natural England are not in agreement with this and highlight the potential for direct impacts through light, noise and dog walking alone. The applicant has submitted a leaflet to mitigate for these impacts but the leaflet alone is not sufficient. The information has not been tailored to this development but is rather a duplicate used to support an application in Holme (p.a. 25/00934/CHSR17). Some of the information in the submitted leaflet is not relevant to this application and needs to be revised. A permanent form of information is also required but has not been proposed or considered.

Further information is required and until such time as that information is submitted I must hold an objection on the grounds of insufficient information to assess the impacts of the proposals on Habitat Sites.