contaminated land strategy

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Contaminated LandInspection Strategy

South Norfolk District Council

JULY, 2001


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CONTENTS

EXECUTIVE SUMMARY

1. INTRODUCTION.....................................................................................................................1

1.1. GENERAL POLICY OF SOUTHNORFOLK DISTRICT COUNCIL................................................ 1

1.2. REGULATORY CONTEXT ..................................................................................................... 2

1.2.1 Regulatory role of local authorities under Part IIA ..................................................... 2

1.2.2 Regulatory role of the Environment Agency ................................................................. 3

1.2.3 Definition of Contaminated Land under Part IIA......................................................... 4

1.2.4 Risk based approach.......................................................... ........................................ 4

1.2.5 Requirements for Strategic Approach.................... ....................................................... 5

1.3. DEVELOPMENT OF THE STRATEGY...................................................................................... 6

1.4. OBJECTIVES OF THE STRATEGY .......................................................................................... 6

2. CHARACTERISTICS OF SOUTH NORFOLK DISTRICT............................................... 8

2.1. GEOGRAPHICAL LOCATION ................................................................................................ 8

2.2. BRIEF DESCRIPTION ............................................................................................................ 8

2.3. HISTORICAL DEVELOPMENT ............................................................................................... 8

2.4. SIZE .................................................................................................................................. 11

2.5. POPULATION DISTRIBUTION ............................................................................................. 11

2.6. LAND OWNED BY THE DISTRICT COUNCIL ........................................................................ 13

2.7. CURRENT LAND USE CHARACTERISTICS .......................................................................... 13

2.8. PROTECTED LOCATIONS ................................................................................................... 13

2.9. KEY PROPERTY TYPES...................................................................................................... 13

2.10. KEY WATER RESOURCE/PROTECTION ISSUES .................................................................. 15

2.11. KNOWN INFORMATION ONCONTAMINATION .................................................................... 16

2.12. CURRENT AND PAST INDUSTRIAL HISTORY ...................................................................... 16

2.12.1 Agricultural Development.................................................................. .................... 19

2.12.2 Military Development....................................................................... ...................... 19

2.13. GEOLOGICAL CHARACTERISTICS ...................................................................................... 20

2.14. HYDROLOGICAL CHARACTERISTICS ................................................................................. 23

2.15. HYDROGEOLOGY.............................................................................................................. 23

2.16. NATURAL CONTAMINATION ............................................................................................. 27

2.16.1 Radon ............................................................... ...................................................... 27

2.16.2 Methane, carbon dioxide and oil susceptibility ..................................................... 27

2.16.3 Soil Geochemistry .......................................................................... ........................ 27

2.17. REDEVELOPMENT HISTORY AND CONTROLS .................................................................... 28

3. SOUTH NORFOLK DISTRICT COUNCIL STRATEGY: OVERALL AIMS ............... 30

3.1. AIMS OF THE STRATEGY.................................................................................................... 30

3.2. OBJECTIVES AND MILESTONES.......................................................................................... 31

4. LOCAL AUTHORITY PRIORITY ACTIONS AND TIMESCALES.............................. 33

4.1. PRIORITIES........................................................................................................................ 33

4.2. TIMESCALES ..................................................................................................................... 33

5. PROCEDURES ......................................................... .............................................................. 34

5.1. INTERNAL MANAGEMENT ARRANGEMENTS FOR INSPECTION AND IDENTIFICATION........... 34

5.2. CONSIDERING LOCAL AUTHORITY INTERESTS IN LAND ..................................................... 34

5.3. INFORMATIONCOLLECTION ............................................................................................. 34

5.4. VOLUNTARY INFORMATION PROVISION AND COMPLAINTS .............................................. 35

5.4.1 Complaints..................................................................................................................35

5.4.2 Confidentiality ............................................................ ................................................ 35

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5.4.3 Voluntary provision of information .................................................................... ........36

5.4.4 Anonymously supplied information................................................ ............................. 36

5.4.5 Anecdotal evidence ................................................................... .................................. 36

5.5. INFORMATIONEVALUATION............................................................................................. 36

5.5.1 Soil ......................................................... ............................................................... ......37

5.5.2 Soil-Gas ........................................................... ........................................................... 37

5.5.3 Controlled Waters.................................................................. ..................................... 37

5.6. INTERACTION WITH OTHER REGULATORY REGIMES .......................................................... 37

5.6.1 Planning ....................................................... ............................................................... .....37

5.6.2 Water pollution.................................................................................................................38

5.6.3 Integrated Pollution Prevention and Control (IPPC)...................................................... 38

6. LIAISON AND COMMUNICATION ................................................................ .................. 39

6.1. STATUTORY CONSULTEES ................................................................................................ 39

6.2. NON-STATUTORY CONSULTEES ........................................................................................ 39

6.3. COMMUNICATING WITH OWNERS,OCCUPIERS AND OTHER INTERESTED PARTIES .............. 396.4. POWERS OF ENTRY............................................................................................................ 40

6.5. RISK COMMUNICATION .................................................................................................... 40

6.6. THE PUBLIC REGISTER...................................................................................................... 40

6.7. PROVISION OF INFORMATION TO THE ENVIRONMENT AGENCY ......................................... 41

7. PROGRAMME AND ARRANGEMENTS FOR DETAILED INSPECTION OF HIGH

PRIORITY SITES............................................................................................................................42

7.1. SITE SPECIFIC LIAISON AND POWERS OF ENTRY ................................................................. 42

7.2. FORMAL DESIGNATION OF CONTAMINATED LAND ........................................................... 42

8. REVIEW MECHANISMS............................................................... ...................................... 44

8.1. TRIGGERS FOR UNDERTAKING INSPECTION ....................................................................... 44

8.2. TRIGGERS FOR REVIEWING INSPECTION DECISIONS ........................................................... 44

8.3. REVIEWING THE STRATEGY .............................................................................................. 45

9. INFORMATION MANAGEMENT.............. ..................................................................... ...46

10. REFERENCES................................................................ ................................................... 47



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Figures

Figure 1. Location of South Norfolk and Neighbouring Districts.............................9Figure 2. Main Settlements in South Norfolk..........................................................12

Figure 3. Areas of Known Ecological Importance ..................................................14

Figure 4. Environment Agency Registered Pollution Incidents and Principal Water

Drainage Features .............................................................................................17

Figure 5. Known Information on Potential Contamination Sources ........................18

Figure 6. Groundwater Vulnerability .......................................................................25

Figure 7. Groundwater Vulnerability (Drift) and Principal Surface Water Drainage

Features.............................................................................................................26

Tables

Table 1. Former USAF Airfields within South Norfolk District.............................. 20

Table 2. Geological Sequence of the District ...........................................................21

Table 3. Hydrogeological Features of the District....................................................24

Table 4. Classification of Stream Sediment Geochemical Data...............................28

Appendices

Appendix 1. Data Audit Findings

Appendix 2. Inspection Timetable

Appendix 3. Receptor Source-Proximity Relative Risk-Screening Model



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South Norfolk District Council

Contaminated Land Inspection Strategy

Executive Summary

Under new regulations that came into force on 1stApril 2000 (Part IIA of

Environmental Protection Act 1990) South Norfolk District Council is required to

inspect land in its district for the purpose of identifying contaminated land. A

strategy must be submitted to the Department of the Environment Transport and

Regions by July 2001. The strategy needs to detail how, in light of the

characteristics of the area, the authority will take a rational, ordered and efficient

approach to this inspection.

The fact that a harmful substance is (in terms of harm to human health, to eco-systems or to property) in, on or under a piece of land does not itself mean that land

is contaminated land. The source of harm may be present but unless a possible

route (plausible pollutant linkage) exists through which it is likely to cause harm

to health, eco-systems or property or to cause pollution of controlled waters, the

land is not contaminated within the meaning of the Act.

Prioritisation is therefore key. Former site uses will need to be taken into account

as will the local geological and hydrogeological conditions but it is the

identification of vulnerable receptors and plausible pollutant linkages, which will

drive the process.

The principal objectives of the strategy are therefore to:

i) meet the statutory requirements to produce a strategy;

ii) use the source-pathway-receptor model as an indication of plausible

pollutant linkages, reviewing the condition of the receptors and moving up

towards potential sources, hence considering immediate concerns to those which

may become apparent in the future;

iii) inform stakeholders of the Councils intentions;

iv) provide information to the Environment Agency for its report on

contaminated land.

The councils priorities in dealing with contaminated land will be to:

i) protect human health

ii) protect controlled waters

iii) protect designated ecosystems

iv) prevent damage to property



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v) prevent further contamination of land

vi) encourage voluntary remediation

vii) encourage re-use of brownfield land

A map - based land categorisation and prioritisation method has been developed at

the strategy stage to enable the identification of minimum information requirements

and the prioritisation of sites to be inspected in more detail.

A programme of inspection over the period 2001 to 2010 has been set out and

procedures identified which take into account information supplied by the public,

business or other organisations; dealing with urgent sites as they arise; and land

owned by the Council and land scheduled for development in the Councils LocalPlan.

The District Council is the lead regulator on contaminated land but, wherever

necessary, the Council will work in partnership with other organisations,

particularly the Environment Agency.

The regulations set clear criteria that must be met before land can be formally

designated as contaminated land . The Council must also maintain a public register

that must contain only certain information.

The strategy is not a static document but subject to continual review. An annualreview process commencing in September 2001 is proposed.



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1. INTRODUCTION

Under new regulations that came into force on 1stApril 2000 (Part IIA of Environmental

Protection Act 1990) South Norfolk District Council is required to inspect land in its district

from time to time for the purpose of identifying contaminated land.

The Secretary of State has issued statutory guidance to local authorities on the implementation

of Part IIA in England. The Statutory Guidance requires local authorities to take a strategic

approach in inspecting their areas and to decide and publish this in a written strategy. This

document details how South Norfolk District Council will undertake this inspection.

1.1. General policy of South Norfolk District Council

The UK has established a policy and legal framework aimed at minimizing the future

incidence of contaminated land; ensuring appropriate action is taken to deal with existing

contamination where it poses unacceptable risks to health and the environment; and

encouraging the reclamation and recycling of brown field land for beneficial use.

In the context of sustainable development, environmental and economic policy areas are key

considerations in developing this Inspection Statutory because they:

ensure unacceptable risks to human health and the environment are reviewed; ensuring a

cleaner and healthier environment for local people and wildlife;

encourage the prudent use of land and social resources;

ensure that the cost burdens of undertaking remediation are proportionate, manageable and

economically sustainable

Land contamination can take a variety of forms and occur in a variety of places. A variety of

people and organizations are therefore likely to take an interest in a contaminated site, whether

contamination has been proven or is suspected.

South Norfolk District Council recognizes that decisions about contaminated land are not made

on a purely technical basis. There will be a variety of regulatory, commercial, financial, legaland social factors, which also affect how particular contaminated land issues should be

addressed. The Council also recognizes that, as with its approach to local government in

general, it is important that decisions about contaminated land are defensible and transparent.

This document is therefore presented as a consultation draft and made available both in hard

copy and on the Councils web site to all groups of people (stake holders) who have an interest

in a contaminated land strategy for the district. Comments received will be considered before

the strategy is finalized and submitted to the Environment Agency.

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1.2. Regulatory Context

The governments main policy statement on contaminated land has been a DOE/Welsh office

paper Framework for Contaminated Land issued in November 1994 which took into accountpublic responses to an interim consultation paper Paying for our Past published in March

1994.

UK policy on land contamination as set out in the Framework, as well as emphasizing the

governments commitment to the environmental principles of sustainable development and the

polluter pays, requires that existing contamination which poses threats to health or

environment is controlled and treated within the suitable for use approach.

The policies in the framework have been implemented primarily through the introduction of the

new contaminated land regime which came into force on 1st April 2000. The statutory basis of

the regime is to be found in Part of IIA of the Environmental Protection Act 1990 (which wasinserted by the Environment Act 1995). Various provisions of the Act have been in force since

the end of July 1995 allowing the Secretary of State to make the all important guidelines which

gives affect to the regime. The guidelines are contained in Annex 3 of DETR Circular 02/2000:

Contaminated Land

It is the introduction of this new regulatory regime generally referred to as the Part IIA regime

that has prompted the production of this strategy document.

1.2.1 Regulatory role of local authorities under Part IIA

The primary regulatory role under the Part IIA regime rests with local authorities. Local

authorities have historically had responsibilities for dealing with any statutory nuisance caused

by land contamination and are the lead authorities on land use planning.

The local authority has a duty under Part IIA to:

cause their areas to be to be inspected from time to time to identify whether any land

appears to be contaminated land;

determine whether any particular site meets the statutory definition of contaminated land;

act as the enforcing authority for all contaminated land, unless the land is required to be

designated as a special site under the Contaminated Land (England) Regulations 2000, in

which case the Environment Agency will act as the enforcing authority. Appendix 4

contains an extract of the Contaminated Land (England) Regulations 2000 containing the

definitions of a special site.

ensure that contaminated land is remediated, and

maintain a register of contaminated land in the district of South Norfolk.



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1.2.2 Regulatory role of the Environment Agency

The Environment Agency has four principal roles with respect to contaminated land under Part

IIA. These are to:

assist local authorities in identifying contaminated land particularly where water

pollution is involved;

provide site specific guidance to local authorities on contaminated land;

act as the enforcing authority for any land designated as a special site, and;

publish periodic reports on the state of contaminated land nationally.

If land is contaminated and falls within one of the descriptions set out in the ContaminatedLand (England) Regulations 2000 it must be designated as a special site. The descriptions of

land do not imply that land of that type is more likely to constitute contaminated land, only that

if the land is contaminated land, the Environment Agency is best placed to be the enforcing

authority. The Regulations also ensure that the Environment Agency becomes the enforcing

authority in three types of case where contaminated land is affecting controlled waters and their

quality, and where the Environment Agency will also have other concerns under the legislation.

The three cases are wholesomeness of drinking water; surface water classification criteria; and

cases where particularly difficult pollutants are affecting major aquifers.

Pollution of controlled waters is to a large extent already regulated by the Water Resources Act

1991, which gives the Environment Agency the power to serve a works notice where pollutionof controlled waters is occurring. However the approach under the regime is to be preferred to

the service of a works notice. To prevent the overlap of jurisdiction between the two Acts, local

authorities are required to liaise with the Environment Agency where pollution of controlled

waters is occurring, or is likely to occur.

Pollution of controlled waters is defined in section 78A(9) of Part IIA as the entry into

controlled waters of any poisonous, noxious or polluting matter or any solid waste matter

For the purpose of the contaminated land regime, entry of pollution into controlled waters takes

place where a contaminant is dissolved, or suspended, in controlled waters, immiscible or has

direct contact with those waters, on or beneath the surface of the water.

Local authorities are warned, however, that land should not be designated as contaminated land

solely on the basis that the substances are already present in controlled waters, where entry of

the substances has ceased, and it is not likely that further entry will take place.



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1.2.3 Definition of Contaminated Land under Part IIA

In the context of existing threats to health or the environment, and where planning or other

environmental protection legislation does not apply, contaminated land is specifically defined inPart IIA of the Environmental Protection Act 1990 as:

any land, which appears to the local authority in whose area it is situated to be in such

condition, by reason of substances in, on or under the land that:

a). Significant harm is being caused or there is a significant possibility of such harm being

caused or

b). Pollution of controlled water is being or is likely to be caused.

Where harm is defined as:

Harm to the health of living organisms or other interference with the ecological systems of

which they form a part, and in the case of man includes harm to his property.

Section 78A (5) requires the enforcing authority to act in accordance with guidance issued by

the Secretary of State in determining significance and likelihood.

1.2.4 Risk based approach

Use of a risk-based approach requires recognition of three main components:

the source: i.e. the hazardous substances on, in or under the ground

the receptor [or target] i.e. the specified entity which is vulnerable, or could be vulnerable, to

the adverse effects of the hazardous substances

the pathway i.e. the means by which a hazardous substance is able to come into contact with a

receptor.

On any individual site there may be one or more of each of these components. However, all

three must be present with a clear relationship or linkage between them, for a risk to exist. The

degree of risk and whether it is sufficiently serious to warrant action depends primarily on thenature of the relationship between these components.

In the context of the Statutory Guidance for Part IIA a source-pathway-receptor relationship is

termed a pollutant linkage.

A risk based suitable for use approach using the concept of source-pathway-receptor

relationships reflects UK Government policy on contaminated land. Under the town and

country planning and building control legislative regimes, risk assessment is based on suitable

for next use (e.g. a change from industrial to residential and therefore a change in receptors).

Under the new contaminated land legislative regime, and the statutory definition of

contaminated land, the risk assessment is based on suitable for current use.



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The receptors recognised as being potentially sensitive in Part IIA are:

Human Beings

Ecological Systems or Living Organisms forming part of a System within certain

Protected Locations, including: Sites of Special Scientific Interest (SSSI), National Nature

Reserves (NNR), Nature Reserves, Special Areas of Conservation (SAC), Special

Protection Areas (SPA), Candidate SACs, RAMSAR sites, Areas of special protection for

birds.

Property in the Form of Buildings, including Ancient Monuments:

Property in other Forms: Crops, Livestock, Home-grown produce, Owned or

domesticated animals, wild animals subject to shooting or fishing rights; and

Controlled Waters: Surface waters (e.g. rivers, lakes, streams), Drinking waterabstractions, Source protection zones, Groundwaters.

In the event that a plausible pollutant linkage is identified and that significant harm is being

caused to a receptor or that risk assessment indicates there is a significant possibility of such

harm occurring or that pollution controlled waters is, or is likely to occur, only then can an area

of land be designated as statutory contaminated land.

If an area of statutory contaminated land has been identified, the approach for dealing with it

will be the same regardless of whether the local authority or the Environment Agency is the

enforcing authority. There are four main stages to this approach.

1. To establish who is the appropriate person to bear responsibility for the remediation (or

clean-up) of the land.

2. To decide what remediation is required and to ensure that this occurs, through: Reaching a

voluntary agreement. Serving a remediation notice, if agreement cannot be reached.

Carrying out work themselves, in certain circumstances.

3. To determine who should bear what proportion of the liability for meeting the costs of the

work.

4.

To record certain information about regulatory action on a public register.

1.2.5 Requirements for Strategic Approach

All local authorities are required to take a strategic approach to the identification of land in their

area which merits detailed individual inspection. The Statutory Guidance requires that the

approach adopted should:

be rational, ordered and efficient;

be proportionate to the seriousness of any actual or potential risk.



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seek to ensure that the most pressing problems are located first.

ensure that resources are concentrated on investigating areas where the authority is most

likely to identify contaminated land and;

ensure that the local authority efficiently identifies requirements for the detailed inspection

of particular areas of land.

1.3. Development of the Strategy

This strategy has been developed with particular reference to Contaminated Land Inspection

Strategies Technical Advice for Local Authorities issued by the Department of the

Environment, Transport and the Regions and has adopted the following approach:

1.

Identification of lead department within the Council for the purpose of the strategy and howeach individual department with an interest in, or input into, the inspection strategy will

liaise with each other.

2. Drafting of a questionnaire for circulation to each of the identified Council departments

covering such aspects as: types of data required and current availability; current data

management and data quality; external contacts and contamination and redevelopment

history.

3. Assimilation of questionnaire responses followed by a data audit to identify and adopt an

initial information gathering strategy as well as identifying an information gathering

strategy for further development during the implementation phase.

4. Preparation of a draft strategy for internal comment by officers from Environmental Health

and Leisure, Treasurers Department (Information Technology/Information Services)

,Central Services (Land Charges and Property Management) and Planning.

5. Submission of the consultation draft for approval by the Councils Policy Development

Panel.

6. Invitation of comments on the consultation drafts from formal and informal consultees.

7.

Submission of a final version of the strategy to the Environment Agency.

1.4. Objectives of the Strategy

The fact that a potentially harmful substance is present (in terms of harm to human health, to

eco-systems or to property) in, on or under a piece of land does not itself mean that land is

contaminated land. The source of harm may be present but unless a possible route (plausible

pollutant linkage) exists through which it is likely to cause harm to health, eco-systems or

property or to cause pollution of controlled waters, the land is not contaminated within the

meaning of the Act.



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Prioritisation is therefore key. Former site uses will need to be taken into account as will the

local geological and hydrogeological conditions but it is the identification of vulnerable

receptors and plausible pollutant linkages which will drive the process.

The principle objectives of the strategy are therefore:

To meet the statutory requirements to produce a strategy;

To use the source-pathway-receptor model as an indication of plausible pollutant linkages,

reviewing the condition of the receptors and moving up towards potential sources, hence

considering immediate concerns to those which may become apparent in the future;

To inform stakeholders of the Councils intentions; and

To provide information to the Environment Agency for its report on contaminated land.



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2. CHARACTERISTICS OF SOUTH NORFOLK DISTRICT

The purpose of this section is to provide the background to South Norfolk District Councils

area and how that influences the Councils approach to inspection for contaminated land. It

will also enable fair comparison with other authorities.

2.1. Geographical Location

South Norfolk District occupies the south eastern part of the county of Norfolk bordered by

other parts of the county to the north and west and Suffolk to the south, as shown on Figure 1.

From some 5km west of Diss to its confluence with the River Yare at Breydon Water, the River

Waveney forms the southern boundary of the district. The city of Norwich, which is the

regional centre, adjoins the District to the north with the District Boundary west of Norwich

marked by the River Wensum and to the south and east of Norwich by the River Yare.

2.2. Brief description

At between 60m and 70m above sea level the central western boundary of the District south of

Wymondham represents the highest part of the area with a general reduction in elevation

towards the east and the marshes at sea level adjoining the lower reaches of the River Yare and

River Waveney.

A gently undulating landscape still dominated by agriculture in terms of land use, however only

a small percentage of people are now directly employed in that industry. South Norfolk has a

diverse range of industries and commercial concerns centered in a rural area of market towns

and villages.

Major trunk roads cross the district, providing good access to London, the Midlands and the

East Coast ports. Two major rail routes traverse the district, which are the electrified line

between London and Norwich and the cross country route between Norwich and Ely.

2.3. Historical Development

There is some evidence that South Norfolk was populated during the pre-Roman times. The

valley of the River Tas was of great importance during pre-historic times and a major

monument existed at Arminghall. Another example of these early times is a primitive field

system near Dickleburgh, which is believed to pre-date the Romans. Pre-historic flint tools have

been found at Caistor.

There is considerable evidence that the Romans settled in South Norfolk. Caistor Roman Town

was a significant fortified settlement on the banks of the River Tas, south of the city of



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Figure 1. Location of South Norfolk and Neighbouring Districts

COUNTY

OF

LINCOLNSHIRE

COUNTY

OF

CAMBRIDGESHIRE

COUNTY

OF

NORFOLK

BROADLAND

DISTRICT

GREAT

YARMOUTH

DISTRICT

NORWICH

BRECKLAND

DISTRICT

SOUTH

NORFOLK

DISTRICT

WAVENEY

DISTRICT

MID SUFFOLK

DISTRICT

COUNTY

OF

SUFFOLK



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Norwich, which did not then exist. The surviving walls and below ground features can be

clearly seen at the site, which is owned by the Norfolk Archaeological Trust. Scole, in the

south of the District, was also settled by the Romans and archaeological finds have included

the remains of a 1,900-year old Roman-Celtic temple and evidence of a considerable settlement

on the banks of the River Waveney. Stoke Holy Cross is known to have been the site of a

Roman Camp.

The Saxon period was a time of growth and wealth for the area. The Saxons built many fine

round-towered churches which are a distinctive feature of South Norfolk. Some of the finest

examples are at Thurton, Hales, Wortwell, the ruined church at Saxlingham and Carleton Rode

Baptist Church.

Wymondham Abbey is the most significant legacy left by the Normans this is the most

important ecclesiastical building in South Norfolk. Hales church is another fine example ofNorman architecture.

The medieval period saw the building of some of our great manor houses. The are several

examples in the District the finest of which is Rainthorpe Hall.

The period from the 15thto the 17thcentury was one of development, particularly of agriculture.

There is a great wealth of yeomans farmhouses and timber-framed barns. The finest example

of these is Hales Barn. Buildings from this period were constructed of wattle and daub over

timber frames; these buildings are a regional characteristic. The ancient market towns of South

Norfolk were established during this time; Diss and Wymondham were both important trading

centres. The 17th

century Market Cross at Wymondham and the Dolphin House at Diss are bothnotable architectural features of these market towns.

The 18thand 19thcenturies were a period of agricultural reform and of unprecedented

population growth. New building materials were introduced into the region and some fine brick

and stone buildings of the period remain. The red brick coaching inn at Scole (formerly the

White Hart) is a good example. The market towns thrived and prospered during this period.

Hingham is a good example where the best collection of Georgian houses in the district

surrounds the green. Other buildings which portray the social and economic conditions of the

time are the 19thcentury Corn Hall at Diss and the workhouses at Pulham. Mills from this

period are a significant landscape feature good examples can be seen at Billingford and

Wicklewood. In more recent times, the economy of South Norfolk has become much morebroadly based, and no longer relies entirely upon agriculture. With the building of the railways,

social conditions changed, and people became more mobile and adaptable.

During the period since World War Two, South Norfolk has seen great changes. There was an

explosion of social housing reform during the great post-war building period. There are

nationally important examples of such houses in the Loddon area, designed by the architects

Tayler & Green.



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2.4. Size

South Norfolk District covers an area of 350 square miles or 906 square kilometres and

comprises 118 parishes.

2.5. Population Distribution

In 1997 the population of the District was estimated at 105,000. South Norfolk District may be

subdivided into three areas of broadly similar geographical extent, the North West, East and

South West areas based on groups of parishes.

Centres of population in the District with more than 2000 inhabitants are as follows.

North West Area Location

Wymondham

New Cotessey

Hethersett

Mulbarton

Cringleford

Hingham

Population

12,010

9,905

5,385

2,930

2,145

2,080

East Area Location

Poringland

Loddon

Population

3,295

2,390

South West Area Location

Diss

Harleston

Long Stratton

Roydon

Population

6,640

4,130

3,310

2,240

More than 40% of the inhabitants of the District live in these centres of population.

Land defined as predominately in urban use by the Planning Department and with a population

of less than 2000 in each of the three areas are:

North West Area Barford, Barnham Broom, Cottessey, Easton, Little Melton,

Newton Flotman, Saxlingham Nethergate, Swainsthorpe,

Swardeston.

East Area Brooke, Burgh St. Peter, Ditchingham, Framingham

Earl,Geldeston, Gillingham, Haddiscoe, Hales, Kirby Row, Low

Thurlton, Norton Subcourse, Rockland St. Mary, Seething, Stoke

Holy Cross, Surlingham, Thurlton, Thurton, Topcroft Street,

Trowse with Newton, West Porlingland, Woodton



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Figure 2. Main Settlements in South Norfolk

Costessey #

Cringleford#

# Hethersett

# Poringland# #Hingham WymondhamMulbarton#

Loddon#

Long Stratton#

Harleston#

Roydon

# Diss#



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South West Area Alburgh Street, Ashwellthorpe, Brockdish, Bunwell Street,

Dickleburgh, Earsham, Forncett End, Fritton, Hempnall,

Needham, Pulham Market, Pulham St. Mary, Scole, Thorpe

Abbotts, Tivetshall St. Mary

2.6. Land owned by the District Council

Approximately 900 title deeds are held covering both current and former District Council

owned land. The current and former site ownership plans are in the process of being digitised

so that an electronic version can be incorporated into the Councils geographical information

system and appropriate spatial queries made on the data.

2.7. Current Land Use Characteristics

South Norfolk is an economy of roughly two parts. To the north, the district is heavily

influenced by the City of Norwich, where many residents are employed. To the south, the

economy is more localised. The districts land use is still devoted mainly to agriculture, but this

sector is no longer significant in terms of employment, employing no more than 8% of the

Districts workforce.

2.8. Protected Locations

South Norfolk contains 26 Sites of Special Scientific Interest (SSSIs). These sites are the best

example of the national natural heritage of wildlife habitats, geological features and landforms.

The 26 SSSIs in South Norfolk cover a diversity of sites ranging from deciduous woodlands

and commons, to river valley meadows. Four of them are identified as being wetland sites of

international importance (RAMSAR sites, named after the city in Iran where the convention

was signed) which are also classified as Special Protection Areas under the European

Community Directive on the Conservation of Wild Birds. These four areas are Surlingham and

Rockland Broads in the Yare Valley; Hardley Flood, east of Chedgrave; and in the Waveney

Valley the Geldeston Meadows and the Stanley and Alder Carrs at Aldeby.

The areas designated as SSSIs are shown on Figure 3, with the majority located in the eastern

part of the District east of the A140.

2.9. Key Property Types

The District has over 3000 Listed Buildings, ** Ancient Monuments and ** designated

Conservation Areas.



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Figure 3. Areas of Known Ecological Importance



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2.10. Key Water Resource/Protection Issues

Anglian Water supply the majority of the Districts drinking water from abstraction boreholesin the chalk aquifer.

The Environment Agency has subdivided groundwater source catchments into four zones

known as Groundwater Source Protection Zones as follows:

Zone I (Inner Protection Zone) - This zone is defined by a travel time of 50-days or

less from any point within the zone at, or below, the water table. Additionally, the zone

has as a minimum a 50-metre radius. It is based principally on biological decay criteria

and is designed to protect against the transmission of toxic chemicals and water-borne

disease.

Zone II (Outer Protection Zone) - This zone is defined by the 400-day travel time, or

25% of the source catchment area, whichever is larger. The travel time is derived from

consideration of the minimum time required to provide delay, dilution and attenuation of

slowly degrading pollutants.

Zone III (Total catchment) - This zone is defined as the total area needed to support

the abstraction or discharge from the protected groundwater source.

Zone of Special Interest - For some groundwater sources an additional "Zone of

Special Interest" may be defined. These zones highlight areas (mainly on non-aquifers)

where known local conditions mean that potentially polluting activities could impact ona groundwater source even though the area is outside the normal catchment of that

source.

A map showing the location and extent of the Groundwater Source Protection Zones can

currently be viewed on the Environment Agencies web-site. There are a number of Source

Protection Zones that are either in South Norfolk or extend into the district. These are as

follows:

Abstraction point Map reference

Bunwell TM 1400 9120

Caistor St Edmund TG 2390 0460

Diss TM 1130 8040

Rushall TL 1980 8340

Stoke Holy Cross TG 2274 0269



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Tivetshall TM 1580 8820

Trowse Newton TG 2411 0606

Billingford TM 1769 7890

Broom Common A TM 3560 9149

Broom Common B TM 3558 9158

Kirby Cane TM 3770 9260

The District Council regularly inspects the quality of 448 private drinking water supplies in itsarea.

Environment Agency Registered Pollution Incidents over the period 1998 to 1999 are shown on

Figure 4 together with the principal surface water drainage features of the District.

2.11. Known Information on Contamination

The Council holds some information on sources of potential contamination from the following

areas; submissions as part of the development control process; complaints from the public;

some premises subject to local air pollution control (eg. the unloading of petrol into storage at aservice station); records on filled and possible filled sites; and potentially polluted sites based

on the local knowledge of the Districts officers. Figure 5 shows the Districts known

information on potentially contaminated sources. It should be noted that whilst Figure 5

includes licensed landfills within 1km of the SNDC boundary in the interest of completeness,

the Part IIA regieme will not normally apply to licensed sites as any pollution problems would

normally be enforced through a condition attached to the site licence.

2.12. Current and Past Industrial History

The principal industry of the District in terms of land use is agriculture with the population ofthe District concentrated in a number of market towns which have developed localised

manufacturing operations. Town gas works were developed in Diss, Harleston and

Wymondham. A feature of the twentieth century was the number of airfields located in the

District over the period 1941 to 1962.



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Figure 4. Environment Agency Registered Pollution Incidents and Principal Water Drainage Features

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Figure 5. Known Information on Potential Contamination Sources

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The district's employers number over 3,000 with more than 75% employing 5 or less and only a

handful of large manufacturing operations. The larger operations include sports car

manufacturing east of Wymondham and engineering and electronics companies in Diss and

Harleston. Smaller scale engineering activities are present in Cotessey and Loddon, with boatbuilding and letting yards also located in Loddon.

Given the wealth of agricultural primary procedure, food-processing activities also features

strongly. There are many small firms involved in all aspects of food processing, with some of

the larger ones based in Little Melton and Harleston.

2.12.1 Agricultural Development

By the late Middle Ages the Norwich area was one of major textile regions of England and the

development reflected a general change from the export of wool to the export of cloth,

particularly after Flemish weavers were allowed to settle in the mid fourteenth century. Thiswas the age of the great wool churches of East Anglia.

The period 1550 to 1750 was one of considerable agricultural innovations. Enclosure of land

had been a continuous process over a long period of time but this accelerated in the sixteenth

and seventeenth centuries. Some areas of open field survived until the Parliamentary

Enclosures Act of 1760 to 1815.

Three types of farming land developed in the region over the period 1640 to 1750 associated

with the characteristics of the soil, and its drainage. The strong loamy soils of the District led to

wood-pasture country. This had more wood and more enclosure, with cattle, not sheep, when

compared with the sandy and light loamy soils of adjoining districts (sheep-corn country).Marshland represented the third farming area.

With the droving of cattle in the eighteenth and early nineteenth century, the region became a

cattle-fattening area. One of the main drove routes ran from Norwich through Long Stratton or

Bungay and Harleston to Hoxne/ Scole; and then to Pakenham, Bury St Edmunds and through

Essex to London.

2.12.2 Military Development

At the all time peak in 1945 Norfolk had the second highest proportionate area of land under

airfields (2.1.%); Suffolk having the highest at 2.4%.

The most common layout was three strips mutually disposed at 60 degrees and linked by a taxi-

track with dispersal bays. The average size of a paved aerodrome in the UK in 1945 was 272

hectares, including dispersed campsites.

The importance of subdued relief (the maximum acceptable longitudinal gradient for a main

land runway in wartime was 1 in 80) and proximity to continental Europe meant that during the

Second World War the District had a very large number of airfields. Some of these are still in

use today for recreational purposes.

None of the RAF airfields were actually operational; RAF Pulham was a Maintenance Unit and



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RAF Stoke Holy Cross was a Radar Station. The airfields at Shotesham, Surlingham,

Bramerton and Burgh St. Peter were Decoy Bases. The area near RAF Burgh St. Peter (the

marshes at Burgh St. Peter, Haddiscoe and Aldeby) was the most heavily bombed part of South

Norfolk.

On the other hand the USAF had a number of bases in the District from which many bomber

sorties were mounted. The seven airfields which wholly or mainly lie within South Norfolk and

their current status are summarised below:

Table 1. Former USAF Airfields within South Norfolk District

Airfield Operational Life Present features

Deopham Green

(NGR TM035995)

1942-1945,

abandoned 1948.

Extensive remains of all 3 runways, part is a public

road.

Fersfield

(NGR TM085855)

1943-1945,

subsequently sold.

Significant lengths of all three runway remains.

Hardwick(NGR TM25905)

1941-1962,RAF control 1945 onwards,

sold 1962.

Parts of the runways and perimeter track. Museumand memorial on the site.

Hethel

(NGR TM155005)

1942-1948,

RAF control 1945 to 1948, sold

1964.

Sold to Lotus Car Company 1964, factory and test

track on parts of the runways.

Seething

(NGR TM318958)

1943-1959,

RAF control 1945 onwards,

Sold 1959.

The Waveney Flying Group operate light aircraft

using part of the former main runway.

Thorpe Abbotts

(NGR TM185805)

1943-1945,

closed 1956.

Only small parts of runway remain. Control tower

restored and contains museum.

Tibenham

(NGR TM145890)

1942-1959,

RAF control 1945 onwards,Part sold in 1952,

Runway extension 1955,

Sold 1964.

The Norfolk Gliding Club use parts of the remaining

runways.

Between 1959 and 1979 the Ministry of Defence sold the following Royal Observer Corp posts

within the District: Aldeby, Diss, Framingham Earl, Harleston, Hellesdon, Hingham, Loddon,

Long Stratton, Wymondham. Cringleford RAF married quarters and The Diss Air Training

Corps Unit were also sold in this period.

Land currently owned by the Ministry Defence within the District comprises Stoke Holy Cross

RAF Radio Site.

2.13. Geological Characteristics

The present surface expression and land use of the District is in part a response to rock type and

as such, some aspects of geological and structural history are relevant.

The primary structural unit providing the foundation of eastern England is the Anglo-Brabant

massif. Beneath most of Norfolk this ancient block of Lower Paleozoic rocks is overlain by

Jurassic and Cretaceous strata which in Norfolk now dip gently south east and east at very low

angles with a minimum of flexuring and faulting.



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The oldest strata that appear at the surface in the District belong to the Cretaceous system. The

geological conditions of the district have been assessed from the following British Geological

Survey 1:50,000 Solid and Drift maps, Sheet 161 Norwich; Sheet 162 Great Yarmouth; Sheet

175 Diss and Sheet 176 Lowestoft.

A summary of the geological sequence is shown in Table 2 below; with the youngest Age

(Holocene) at the top.

Table 2. Geological Sequence of the District

Period Age Geological Unit Characteristics

Quaternary Holocene Alluvium Soft clays, sand, silt and

peat.

Pleistocene River Terrace Deposits Sand and gravel, locally

clayey.

Glacial Sand and Gravel Sand and gravel, locally

clayeyGlacial Till Stiff, chalky, pebbly

sandy clay.

Kesgrave Sands and Gravels Sand and gravel.

Norwich Crag Sands and gravels, shelly

sands.

Tertiary Eocene London Clay

(Thames Group)

Stiff, blue-grey clays,

sandy at base.

Reading beds

(Lambeth group)

Stiff, mottled clay.

Mesozoic Cretaceous Upper Chalk Fine grained fissured

white limestone with

bands of flint nodules.

On account of its great thickness (attaining a maximum thickness of approximately 400m in

Norfolk), and its regular lateral extent, the Chalk is the dominant formation in the area. The

Chalk dips eastward at less than 1 degree and thickens in the same direction. It is covered by

thick Pleistocene and, in the east of the District, Eocene deposits. As such, the Chalk only

outcrops in the District on the sides of the River Yare south and west of Norwich and along the

River Tas.

After a long period of steady subsidence during which the Chalk was deposited the whole area

was raised as a land-mass and acted upon by the agents of erosion; it was also subject to gentletilting at this time. Eventually, the southeastern part of England was invaded by a sea which

laid down some of the earliest deposits of the Tertiary period. Within the District the Eocene

deposits are present overlying the Chalk broadly east of a line from Claxton in the north, to

Mundham and Ellingham on the Waveney valley in the south. These strata are overlain by later

deposits and are not exposed at the surface within the District.

Following partial submergence of the eastern part of the District beneath a precursor of the

present North Sea, the next series of marine deposits were laid down in the early Pleistocene.

These deposits, consisting chiefly of shelly sands, pebbly gravels and sands, extend over the

eastern parts of the District, and the term Crag, a word used locally for any shelly sand, is



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currently employed to denote them. Norwich Crag is present beneath the District east of the

Norwich-Diss railway line but is only exposed at the surface on the eastern side of the Tas

Valley at Stoke Holy Cross and along the Yare Valley to the west and south east of Norwich.

Terrestrial sedimentation in the Middle Pleistocene is represented by the Kesgrave Formation of

the Thames and deposits of its tributary rivers.

The region experienced glaciation on at least two occasions, during the Anglian and Late

Devensian. During the Anglian, the Lowestoft Formation (chalky, pebbly, sandy clay (till) and

sands and gravels) was deposited by British-based glaciers and the North Sea Drift Formation

by a Scandinavian ice-sheet that impinged upon parts of northeast Norfolk, in land as far as

Diss.

Evidence of fluvial activity is significant with major re-organisation of the drainage system as a

result of glaciation during the Anglian.

Glaciofluvial gravels overlie the till in many places, as for example, along the Yare valley, the

Wensum and some of its tributaries.

The later Middle Pleistocene is known from numerous localities where temperate-phase organic

sequences have been identified as for example, at Dunston Common or Barford, where a deep

channel cut into the Chalk to 35m below sea level has been infilled with chalky till on which

rests extensive organic clays up to 9m thick.

Fluvial deposition during the later Middle and Late Pleistocene produced extensive sand and

gravel river terrace deposits along the major valleys under a cold climate.

Within the last 10,000 years and primarily in response to rising sea levels since the last

glaciation, alluvial deposits of sand, silt, clay and peat have accumulated in the lower reaches of

the Yare and Waveney valleys, creating extensive areas of poorly drained marshland. During

medieval times broads were excavated for their peat and later flooded. Two such areas are

located within the district on the right bank of the River Yare - Surlingham Broad and Rockland

Broad.

The two principal factors in the Quarternary history of the district were climatic oscillations and

associated changes in sea level. Deposits from the period are seen now as a mantle of clays,

sands and gravels and, locally, peat and it is to these that the aspect and agricultural characters

of the land are mostly due.



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2.14. Hydrological Characteristics

The District is characterised by an eastward flowing surface drainage system which combines atwhat is almost the Districts most easterly point, the entrance to Breydon Water.

The River Wensum, west of Norwich, and the River Yare, south and east of Norwich, mark the

Districts northern boundary. The River Tud runs parallel with, and to the north of, the A47 in

the northern tip of the District before joining the Wensum to the east of New Cotessey.

Three named right banks tributaries join the River Yare as it passes along the northern

boundary of the District the north-northeasterly flowing River Tiffey which passes through

Wymondham before joining the Yare at Barford; the north-northeasterly flowing River Tas

which drains the central area of the District around Long Stratton and joins the Yare at Trowse

Newton; and the eastward flowing River Chet which joins the Yare east of Loddon.

Along the southern boundary of the District the River Waveney, flowing east-northeast, has

created a steep-sided, flat floored and somewhat sinuous valley through glacial deposits

between Diss and Bungay. Westward of Diss the valley merges with that of the Little Ouse

River. Both rivers now rise in the peat of Redgrave Fen at about 25m above sea level, but flow

in opposite directions.

Only one named left bank tributary joins the River Waveney as it passes along the Districts

southern and eastern boundaries Broome Beck, which joins the Waveney between Broome

and Ellingham.

The River Yare is tidal below its confluence with the River Tas at Trowse Newton. The River

Waveney is tidal below Benstead Marshes, just after the confluence of Broome Beck. The

River Chet is also tidal below Loddon.

The principal surface water drainage features are shown on Figure 4.

2.15. Hydrogeology

The hydrogeological conditions of the District have been assessed from the British Geological

Survey 1:125,000 scale hydrogeological maps of Northern and Southern East Anglia togetherwith relevant Environment Agency Groundwater Vulnerability Maps (sheets 26 and 33,

1:100,000 scale), and the Environment Agency Policy and Practice for the Protection of

Groundwater Anglian Regional Appendix.



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A summary of the hydrogeological features of strata within the District is shown below

Table 3. Hydrogeological Features of the District

Strata type Hydrogeological Characteristics Flow Mechanism GeologicalClassification

Alluvium Floors the main valleys, variable thickness; peat has

suffered saline intrusion in the tidal reaches of the

Yare and Waveney.

Intergranular Minor Aquifer

River Terrace

Gravels

Occurs sporadically in the river valleys, notably the

Wensum and Waveney. Water saline in the lower

reaches of the Yare and Waveney and in the adjoining

marshlands.


Glacial Sands

and Gravels

Occurs as masses within and beneath the Glacial Till

and in places above it. Small yields have been

obtained from Glacial Sands overlying Crag.


Glacial Till Chalky boulder clay is the predominanttype of till, commonly 30 to 50m thick and covering

large areas of the District; limits infiltration into the

Crag and chalk aquifers. Doesnt yield much water

but small supplies may be obtained from interbedded

sands.

Varied Minor Aquifer

Crag Interbedded sands and gravels and shelly sands,

present in the District east of the A140; dips and

thickens generally eastward reaching a thickness of

70m at the coast but only exposed in main valleys.

West of Eocene base Crag and Chalk in continuity.

Predominantly

intergranular

Major Aquifer

London Clay

(Thames

Group)

Blue-grey clays sandy at base, present in the District

east of line joining Claxton, Mundham and Ellingham

dipping and thickening eastwards reaching a thicknessof 95m at Great Yarmouth. Not exposed at surface

and essentially non-water bearing.

Predominantly

intergranular

Non Aquifer

Reading Beds

(Lambeth

Group)

Mottled clays, present in the District east of a line

joining Claxton, Mundham and Ellingham. Not

exposed at surface and essentially non-water bearing.

Intergranular Non Aquifer

Upper Chalk Fine grained fissured white limestone with bands of

flint nodules, the principal aquifer of Norfolk.

Covered by thick Pleistocene deposits and in the east

of the District, Eocene deposits. Chalk surface

dissected by buried channels cut by sub-glacial

streams and infilled with Pleistocene deposits.

Exposed only major valleys in the District. Most

water boreholes exploit the top 30 to 60m of the

Chalk.

Fissure Major Aquifer

The Upper Chalk is an aquifer of regional importance. The Chalk water table reflects surface

topography in a modified form and is at greatest depth below high ground. Beneath thick

deposits of glacial till the Chalk groundwater is confined under pressure. Artesian flow, often

seasonal, has been recorded in a number of localities in the Wensum valley and the Tas valley.

In the western part of the District beneath the higher ground between Wymondham and Diss (at

some 65m to 75m above sea level), the ground water level in the Chalk is at approximately 40m



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Figure 6. Groundwater Vulnerability



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Figure 7. Groundwater Vulnerability (Drift) and Principal Surface Water Drainage Features

River Wensum

River Tud

River Yare

River Tiffey

River Tas

River Chet

Broome Beck

River Waveney

River Yare

River Waveney



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above sea level. From here the water level reduces in elevation in a generally easterly direction

until it is at sea level (Om Ordnance Datum) along the marshes adjoining the lower reaches of

the Yare and Waveney. A groundwater vulnerability map for the District is shown on Figure 6.

This indicates almost the whole District being classified as a major aquifer overlain by soils ofhigh, intermediate and low leaching potential. However as indicated above and in Section 2.13

, much of the Chalk aquifer is also overlain by low permeability non-water bearing drift

deposits occurring at the surface. The groundwater vulnerability in relation to the drift deposits,

together with the principal surface water drainage features, is shown on Figure 7.

2.16. Natural Contamination

Three areas have been reviewed from existing information published by the British Geological

Survey (BGS) and in the Soil Geochemical Atlas of England and Wales. These are:

radon and background radioactivity from natural sources;

methane, carbon dioxide and oil seeps from natural sources and mining areas;

potentially harmful elements from natural sources and mining areas.

2.16.1 Radon

BGS information at 1:625,000 scale indicate that based on their classification of the underlying

rocks, the District falls within the low to moderate Radon Potential Class. The ground is

susceptible to low levels of radon emissions but with small sub-areas susceptible to moderate orhigh levels of radon emissions. Less than 1% of dwellings are estimated to be exceeding the

200 Bqm3Action level, the lowest classification class. Whilst the existing Part IIA regime does

not at present apply with respect to harm, or water pollution, which is attributable to any

radioactivity possessed by any substance, the Secretary of State does have powers to make

regulations to deal with the problem of radioactive contamination.

2.16.2 Methane, carbon dioxide and oil susceptibility

BGS information at 1:625,000 scale indicates that the district has a low susceptibility to

methane and carbon dioxide emissions and oil seeps at the surface and underground from

natural sources.

2.16.3 Soil Geochemistry

A study in the early 1980s, based on less than 2mm fraction of soils and taken from a depth of

0 to 0.15m below ground level, sampled the non-urban landscape on a 5km grid across the

country (i.e one sample every 25km2).

Within the District this indicated low concentrations of heavy metals in the soil: cadmium less

than 1mg/kg, (locally 1 to 2 mg/kg); chromium less than 150mg/kg; copper less than 50mg/kg;

lead less than 50mg/kg (locally 50 to 150 mg/kg); nickel less than 30mg/kg; and zinc less than

150mg/kg.



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In 1995 the BGS produced maps at a scale of 1:625,000 entitled Distribution of Areas with

above National Average Background Concentrations of Potentially Harmful elements (As, Cd,

Cu, Pb and Zn). This was based on stream sediment data on either one sample per 1.6km2or

one sample per 2.5km2. A computer procedure then classified the country in 1km grid squares

based on the highest level recorded for any grid square. The BGS data indicated the following

ranges for classification of gridded stream sediment geochemical data (mg/kg):

Table 4. Classification of Stream Sediment Geochemical Data

Element Data set National average

Background (Bk)

Bk-


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reparation of policies and proposals for the next Local Plan over the period 2001 to 2005.



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3. SOUTH NORFOLK DISTRICT COUNCIL STRATEGY:

OVERALL AIMSIn developing its strategic approach, the Council has taken due regard of its local

circumstances and currently available information. This has enabled preliminary consideration

of the following aspects:

available evidence that significant harm or pollution of controlled waters is actually being

caused;

the extent to which human and ecological receptors and controlled waters are likely to be

distributed within different parts of the authoritys area;

the extent to which those receptors are likely to be exposed to a contaminant as a result of

the use of the land or the geological and hydrogeological features of the area;

the extent to which information on land contamination is already available;

the history, scale and nature of industrial and military activities which may have

contaminated the land in different parts of the District;

the nature and timing of past redevelopment in different parts of the District;

the extent to which remedial action has already been taken by the authority to deal with

land-contamination problems, or is likely to be taken as part of the Districts Local Plan and

Development Plan for its area.

This section sets out the Councils particular aims and objectives.

3.1. Aims of the strategy

In accordance with the requirements of a strategic approach set out in Section 1.2.5 a prioritised

list of the Councils aims has been devised to aid decision-making in a cost effective manner.

The Councils priorities in dealing with contaminated land will be to:

i) protect human health

ii) protect controlled waters

iii) protect designated ecosystems

iv) prevent damage to property

v) prevent further contamination of land



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vi) encourage voluntary remediation

vii) encourage re-use of brownfield land

The list is presented in priority order and in all cases will have regard to significance andlikelihood, as required by the regulations.

3.2. Objectives and milestones

The inspection strategy will use the source-pathway-receptor model as an indication of

plausible pollutants linkages, reviewing the condition of the receptors and moving up towards

potential sources, hence considering immediate concerns to those which may become apparent

in the future.

A map-based land categorisation and prioritisation method using a receptor source proximityrelative risk model has been developed at the strategy stage to enable the identification of

minimum information requirements. These requirements are:

Current land use plans

Locations of current and former landfills and other areas of filled ground

Locations of groundwater abstraction wells, both public and private

Current surface water classification under the Environment Agencys General Quality

Assessment Chemical Grading for Rivers and Canals Scheme and the river ecosystemclassification under the Surface Waters (River Ecosystem Classification) Regulations 1994.

Location of statutory and non-statutory sites of ecological importance

Potential sources of contamination based on the industries listed in the DOE Industry

Profiles.

The current and historical locations of these industries based on current and historical

Ordnance Survey maps.

Assimilation of questionnaire responses from the various departments within the Council,followed by a data audit, has enabled existing information of relevance to the strategy to be

identified together with information gaps which will need to be addressed and prioritised. A

summary of the data audit is presented in Appendix 1.

South Norfolk District is essentially a rural area with the population concentrated in relatively

few towns and large villages. (Figure 2 and Section 2.5 refers.) The Councils first priority in

dealing with contaminated land is to protect human health. Given that the limited industrial

development in the District is also focused in the main centres of population the urban areas are

at the highest risk of having all three elements of a pollutant linkage (source, pathway, receptor)

which could cause significant harm to human health.



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As such, an indicative first order approximation could screen out the majority of the District.

However, the land uses associated with particular types of receptor also need to be considered

together with potential sources of pollution outside the urban areas. The strategy will therefore

also need to address the following aspects:

the accuracy to which the various data sets can realistically be resolved (for example,

proximity of sources of contamination to particular receptors to less than 50m);

the necessity to undertake some preliminary (visual) inspection of the District on a fairly

cursory basis (eg. walk/drive around the area) targeted at specific issues;

the use of the Councils Geographical Information System (GIS) to manage contaminated

land information;

the use of a scoring system to assist in assigning a priority to various areas of land and

decide which areas of land are likely to justify more detailed individual inspection;

evidence of an existing problem;

likelihood that past remediation work has reduced the potential for the presence of

contamination sources;

imminent redevelopment proposals where the potential for contamination is being addressed

by the planning and development control system;

highlight areas identified by the Local Plan which are expected to undergo development

before the next review data identified in the Inspection Strategy;

assessment of land for which the Council may be the appropriate person;

information provided to the Council by other statutory bodies (eg. Environment Agency,

MAFF, conservation/heritage bodies);

information provided to the Council by businesses, the general public or other organisations

or individuals.

To meet the aims of the strategy and information requirements of the receptor source-proximity

model, the inspection process has been summarised as a series of activities with target dates forcompletion. This is presented as Appendix 2.



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4. LOCAL AUTHORITY PRIORITY ACTIONS AND

TIMESCALESThis section describes the focus of the specific approach of the Council, reflecting the context

set out in Sections 1and 2 and the particular aims and objectives set out in section 3.

4.1. Priorities

The first activity after strategy publication will be the requirement to obtain information on

current land use, local authority owned land, and public and private water abstraction points.

The land use categories will be: housing; schools; allotments; informal play areas; playing

fields; public open space, commercial development; industrial development; agriculture. Thisdata will be plotted on appropriately scaled maps of the District.

Data on important protected habitats, surface water features and positions of known/suspected

filled sites are shown in Figures 3, 4 and 5 respectively at a scale of 1:150,000. The accuracy of

these and other data sets at a more detailed scale will be reviewed.

Historical geo-referenced Ordnance Survey maps of the District will be purchased at scales

appropriate to the characteristics of the area. An annual strategy review will be implemented

commencing in 2001. Prior to the first review any information provided by the public, business

or other organisation during the period April to August 2001 will be assessed. Information

provided during the period September 2001 to September 2002 will be incorporated into theReceptor Source-Proximity Zone Plan as appropriate. Prior to the first review the capability of

the councils Geographical Information System to manage contaminated land information will

be reviewed.

4.2. Timescales

The timescales for the prioritised activities identified in 4.1 are shown in Appendix 2 and

primarily cover the period July 2001 to March 2010.



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5. PROCEDURES

5.1. Internal management arrangements for inspection and identification

Within the District Council, the Environmental Health Department has responsibility for the

implementation of Part IIA of the Environmental Protection Act 1990. As part of the

Environmental Health and Leisure Team, the Senior Environmental Health Officer (Pollution)

is the lead officer on contaminated land , reporting to the Principal Environmental Health

Officer and the Deputy Chief Environmental Health and Leisure Officer.

A Contaminated Land Working Group will be established, led by Environmental Health, but

also comprising representatives from Central Services (Land Charges and Property

Management), Treasurers Department (Information Technology/Information services), and

Planning. Priority activities identified in the Inspection Timetable in Appendix 2 encompass

inputs from all these departments. To ensure a co-ordinated approach the working group will

meet on a quarterly basis during Year 1 (June, September and December 2001 and March 2002)

and annually thereafter as appropriate.

The Senior Environmental Health Officer (Pollution) will deal with the day-to-day

implementation of the strategy once approved by elected members. The Senior Environmental

Health Officer (Pollution) will also be responsible for serving remediation notices, subject to

consultation with the Deputy Chief Environmental Health and Leisure Officer and the

Councils solicitor.

Elected members will be informed at the earliest opportunity of any plans to designate an area

of council-owned land, or where the Council is the appropriate person and may be liable for

remediation costs.

5.2. Considering local authority interests in land

As indicated in Sections 2 and 3, South Norfolk District Council holds approximately 900 title

deeds on current and former sites owned by the Council. Assessment of this land has been

identified as a priority in Appendix 2.

5.3. Information Collection

The questionnaire circulated to various departments within the Council identified a number of

information sources to identify potential sources of contamination, potential receptors and the

nature of potential pathways. These information sources were broadly classified under the

headings of conservation data; geology; hydrology; hydrogeology; land use; and natural

contamination.

A summary of the currently available data types and their attributes is provided in Appendix 1.



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The receptor source-proximity relative risk-screening model is provided in Appendix 3.

5.4. Voluntary Information Provision and Complaints

Information may be provided to the Council by the general public, businesses or other

organisations or individuals either as a complaint regarding contaminated land or voluntarily

relating to land contamination that is not directly affecting them. Procedures to address these

complaints or acts of information provision are detailed here.

5.4.1 Complaints

A complaint regarding contaminated land will be dealt with following the same procedure as

currently used by the Environmental Health and Leisure Department to deal with statutory

nuisance complaints.

All complainants may expect:

their complaint to be logged and recorded

to be contacted by an officer regarding their complaint within three working days of receipt

to be kept informed of progress towards resolution of the problem.

Every effort will be made to resolve complaints quickly and efficiently. It must be recognised

however, that the legislation requires the following process in the designation of contaminated

land:

i) proof of a viable pollutant linkage before any formal designation as contaminated land is

permissible, which might only be possible with detailed investigation

ii) prior consultation with interested parties before determination as contaminated land

iii) a minimum of a three month period between determination and serving of a remediation

notice

iv) the requirement for the enforcing authority to make every effort to identify the original

polluter of the land (or Class A person)

The regulations allow conditions (ii) and (iii) to be waived in extreme cases, but not conditions

(i) and (iv).

Complaints will be assessed as a source of information in the development of the prioritised

receptor source-proximity model and final identification as appropriate.

5.4.2 Confidentiality

All complainants will be asked to supply their names and addresses and, if appropriate, the

address giving rise to the complaint. The identity of the complainant will remain confidential.



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The only circumstance in which this information might be made public would be in the case of

a remediation notice being appealed in a court of law and an adverse effect on the

complainants health was an important reason for the original contaminated land designation.

5.4.3 Voluntary provision of information

If a person or organisation provides information relating to contaminated land that is not

directly affecting their own health, the health of their families or their property, this will not be

treated as a complaint. The information will be recorded and may be acted upon. There will,

however, be no obligation for the Council to keep the person or organisation informed of

progress towards resolution, although it may choose to do so as general good practice.

5.4.4 Anonymously supplied information

The Council does not normally undertake any investigation based on anonymously suppliedinformation, and this general policy will be adopted for contaminated land issues. This policy

does not, however, preclude investigation of an anonymous complaint in exceptional

circumstances.

5.4.5 Anecdotal evidence

Any anecdotal evidence provided to the Council relating to contaminated land will be noted, but

no designation of contaminated land will occur without robust scientific evidence. In all cases,

the Environmental Co-ordinator will use knowledge and experience to decide what, if any,

further investigation is required following a complaint or a provision of information.

5.5. Information Evaluation

All information on substances in, on or under the ground that may cause significant harm or

pollution will be evaluated against current governmental guidelines.

Model Procedures for the Management of Contaminated Land have been developed by the

DETR contaminated land research programme and are due to be published shortly. These

incorporate existing good technical practice including the use of risk assessment and risk

management techniques, into a systematic process for identifying, making decisions about and

taking appropriate action to deal with contamination, in a way which is consistent with UKpolicy and legislative requirements. When available, the procedures will be incorporated into

the management protocols of the inspection strategy.



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5.5.1 Soil

Current generic guidelines for a range of contaminants in soil is provided by the

Interdepartmental Committee on Redevelopment of Contaminated and ICRCL 59/83 (2nd

edition 1987), Guidance on the assessment and development of contaminated land and the

Contaminated Land Exposure Assessment or CLEA guidelines.

Risk assessments may also be required for substances not covered by ICRCL or CLEA

guidelines. This will either be addressed via generic guidelines and standards adopted in other

countries (with due regard to the fact these criteria have been developed to support particular

policy and/or regulatory frameworks in the country of origin which may di

contaminated land strategy

Documents