The National Planning Policy Framework (the NPPF) places great weight on protecting and enhancing the natural environment. It seeks to ensure that development not only avoids harm to natural environmental assets but also encourages Local Plans to actively protect, promote and enhance biodiversity so that development results in net gain (paragraph 174).

An Interim Habitats Regulations Assessment (HRA) has been published alongside the Local Plan Regulation 18, Stage C Consultation Document. This deals specifically with the potential impact of the draft Local Plan Growth Strategy on designated ecological habitats, including the Broads and the Norfolk Coast in accordance with the NPPF.

The HRA identifies a range of mitigation measures that may assist in alleviating recreational pressure from new housing sites identified in the Regulation 18, Stage C Consultation Document. These include (i) the provision of new, alternative green space (referred to in the HRA as SANGS) and (ii) a programme of improvements to existing areas of infrastructure. The HRA confirms that the SANG could take the form of a new country park containing woodland and waterbodies.

This need for additional, useable and attractive green infrastructure within Greater Norwich in order to mitigate proposed growth is not a new one. The Greater Norwich Development Partnership (GNDP) undertook an Open Spaces Indoor Sports and Community Recreation Assessment (OSISCRA) using Planning Policy Guidance 17 (PPG17) assessment methodology in September 2007.

This OSISCRA concluded that there was a requirement in 2007 to deliver 87.5 sq. m of combined formal, seminatural, amenity, play, sports and outdoor spaces per person resident in South Norfolk Council area. The OSISCRA went on to conclude that South Norfolk Council did not have a large enough network of public open spaces (at the start of the adopted Joint Core Strategy review) to meet the needs of the District.

Since 2007 this Habitat Regulations problem within South Norfolk has worsened due to large scale housing growth and the Council’s failure to implement a strategy to deliver new natural and semi-natural green spaces to manage this impact.

Whilst the current Joint Core Strategy identifies the potential to create a new country park at Bawburgh Lakes to mitigate the impact of its growth strategy, this site remains undelivered. The Joint Core Strategy for Norwich, Broadland and South Norfolk Annual Monitoring Report strategy 2016-2017 published April 2018 (AMR) has since confirmed that there has been no net increase in the amount of natural and semi-natural open spaces delivered within South Norfolk Council area since the 2007 assessment and thus the impact of the existing Local Plan growth strategy remains unmitigated.

Despite this and the requirement for new SANGs to mitigate the additional recreational pressure to be created by the emerging Local Plan, there is no site identified within the Regulation 18 Stage C Consultation Document for a new Country Park. To the contrary, footnote 74 of the Regulation 18, Stage C Consultation Document defers consideration of potential sites for a new Country Park to the Regulation 19 stage.

In the absence of any identified deliverable sites for a Country Park within the Regulation 18, Stage C Consultation Document, draft Policy 3 requests that new development provide onsite infrastructure as necessary. In addition, and rather than allocating sites, the plan suggests that new country parks can be identified through green infrastructure strategies and be funded in the most part, by CIL.

Glavenhill Ltd contend that the GNGB’s approach to the natural environment as set out in Policy 3 of the Regulation 18, Stage C Consultation Document, specifically the lack of any discernible or deliverable site for a new country park, is ‘unsound’.

Glavenhill Ltd request that before any further strategic scale growth can be planned through the Greater Norwich Local Plan, that South Norfolk Council establish a proposal for a realistic and deliverable new network of SANG’s. This could be achieved in part, through the allocation and early release of a Country Park at Caistor Lane (GNLP 0485).

The proposed Country Park at Caistor can be delivered at a scale and in a form that ensures its attractiveness to new visitors, thus diverting visitors away from The Broads National Park and existing Natura 2000 sites, SAC’s and SSSI’s present within the District.

Importantly, the set-up and long-term maintenance of this new park will be funded by housing delivery across the same site and would not be reliant on the public purse.