Paragraph 98 describes the need to maintain water quality to prevent damage to protected sites. This statement needs further clarification and the statements in paragraphs 106 and 107 should be further qualified to mention the potential conflict between maintaining river flows and ensuring no adverse impact on protected sites and species; and the need as a public water supply.

In paragraph 105 the focus seems to be on soil management for agricultural purposes with Map 6 showing a solely agricultural perspective. No mention is made of the impact of poor soil management on the riparian habitats. Equally mention needs to made of the value of the peat and chalk soils especially in the Wensum valley and the role of peat soils in capturing carbon.
It is difficult to comment on statements as described in paragraph 107 where mention is made of the area being categorised as suffering from serious water stress and solutions to overcome this state being managed by another company and another plan, the details of which are not available. Clarification is needed to describe the mechanisms by which serious water stress will be overcome

Paragraph 98 states that the GNLP will need to ensure development does not have a negative impact on designated sites but does not offer any further detail as to how this will be achieved. This lack of detail makes it difficult to provide constructive comments to improve the quality of the plan and facilitate successful delivery.

Paragraph 101 mentions long-term work is being undertaken to improve green infrastructure, but no further detail or is provided. Providing this information will help us to provide constructive comments to improve the quality of the plan and facilitate successful delivery.

Paragraph 101 also mentions providing biodiversity buffer zones as a means of controlling the impact on protected areas. This statement contradicts the findings described within the Habitats Regulation Assessment which categorically states there will be no adverse impact on protected habitats and protected species.

As a point of detail, the HRA should describe the impact of the activity in terms of ‘likely significant effect.’

Another failing of the HRA is its consideration of potential sources of impact on designated sites and designated species in isolation. RSPB has shown that a combination of impact sources leads to damaging events on sites and species.

We suggest the HRA needs further work to incorporate this ‘in combination’ aspect.

People will naturally gravitate to the best parts of the countryside, often next to rivers with views. Mitigation is needed to cover the cost of deterioration of infrastructure at these locations, as well as enhancing facilities and their management and promoting sustainable access.

Paragraph 104 describes policies to protect landscapes but provides no further explanation as to what the mechanisms are by which this will be achieved. It is hard to understand and comment on potential negative or positive impact without any detailed information.

Paragraph 107 makes the statement increased efficiency in water and energy use will have minimised the need for new infrastructure but neglects to describe there is still the basic need to extract from source. This comment aligns with our comment 4. above. Additionally, we would suggest that protection of the water resource and water quality goes beyond new water efficient buildings and these form only a fraction of the existing residential and commercial building resource. How will the lessons learnt from the new build be conveyed and implemented across existing infrastructure to help change failing Water Framework Directive status of rivers and water bodies in the Broads?

Additional increased growth will compound existing issues around water provision, water quality, Nitrogen and ammonium deposition.

Figure 4 does not show the marine protected areas off the Norfolk Coast. As a minimum, the Outer Thames Estuary SPA and Greater Wash SPA should be identified. This is important when considering in-combination assessments in the HRA, as features of these sites that breed on beaches could be impacted by increased recreational pressure from new development within Greater Norwich.