Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 21762

Received: 16/03/2020

Respondent: RSPB (East of England Regional Office)

Representation Summary:

Careful consideration of water impacts (quality and quantity) will be required to demonstrate that there definitely will not be any adverse effects on integrity of Natura 2000 and Ramsar sites.

Full text:

Good to see a more rigorous approach being applied to water management and adopting more demanding standards. Although the GNLP focuses on new build (as mentioned in comment 13 above related to paragraph 107) what additional benefits could be gained from improvements to existing residential and commercial buildings?
Given water is such a vital resource and comments have been made regarding the serious water stress status of the area, how successful has Anglian Water’s ‘love every drop’ campaign been and do they propose continuance and escalation of this approach?
A fully updated and signed off water cycle study will be required to inform decisions about what is appropriate. This will be necessary to inform HRA conclusions and ensure that adverse effects on integrity will be avoided.
The RSPB is disappointed that HRA conclusions suggest the plan will be sound as there will not be any adverse effects on integrity of Natura 2000 and Ramsar sites, but in several areas this is due to reliance on plans that have not yet been completed such as the Norfolk RAMS and GI Strategy. Until such plans and approaches are finalised, they cannot be relied upon and cannot be taken to as a measure to demonstrate that the GNLP policies will be sound. The RSPB looks forward to seeing revised HRA recommendations based on an evidence base that is final and has certainty that it will be in place by the time the plan is adopted.