Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21829
Received: 16/03/2020
Respondent: Natural England
Information provided under ‘The natural environment’ section needs to be improved and expanded as it currently is unclear or incomplete. It needs to recognise and include the issues that the natural environment, both within and adjoining the Plan area, is facing including biodiversity loss, climate change, habitat fragmentation, pollution etc and how the proposed Plan may impact on and address these issues. Currently, it could be read as the only issues facing our natural environment are those identified under (98), which is clearly not the case.
(97) Under (97) and throughout the Local Plan all references to ‘Natura 2000 sites’ should be replaced with ‘European Sites’ since Britain has left the European Union. It would be helpful to explain that in the National Planning Policy Framework (NPPF) these are referred to as ‘habitats sites’ as it is unclear from the text and Map 4 Major Habitat Sites in Norfolk nor are the abbreviations in the legend on the map explained. In addition to Map 4, a separate map (or series of maps) should be included which clearly illustrate the other natural environmental assets found within or adjacent to the GNLP area.
(98) This section needs to be expanded and made clearer with the impacts resulting from growth on water quality and water resources separated from recreational disturbance impacts. The Plan needs to recognise that recreational disturbance impacts affect not just internationally designated sites, but a wide range of other sites that are important for wildlife, including County Wildlife Sites (CWS).
(101) It needs to be clearly stated here that the existing green infrastructure (GI) network needs to be protected from further loss and severance, as well as new GI being created. Mention should also be made of the vital role of GI in:
supporting biodiversity
combating climate change
reducing pollution
helping to create attractive homes and places to work
enhancing landscapes
reducing flood risk, and
contributing to wellbeing
The Plan needs to recognise that the protection and delivery of quality GI is key to delivering many of its objectives and growth cannot be regarded as being sustainable without this. In particular the Local Plan should promote the delivery of a strategic green infrastructure network that is resilient to the scale of development proposed, capable of protecting designated sites and supporting habitat, and delivering the wider range of environmental services to meet development needs.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
We support Broadland District, Norwich City and South Norfolk Councils’ preparation of a joint Local Plan to ensure a consistent approach to planning across the Greater Norwich area, with policies aligned with the revised National Planning Policy Framework (NPPF).
We have made detailed comments in this letter in relation to the following Greater Norwich Local Plan (GNLP) consultation documents:
Draft Local Plan – Part 1 The Strategy
Draft Sites Document
Habitats Regulations Assessment of GNLP, December 2019
Sustainability Appraisal and Strategic Environmental Assessment, January 2020
Natural England acknowledges that the findings of supporting documents including the draft Greater Norwich Water Cycle Study (WCS) (AECOM 2019) and the emerging Green Infrastructure and Recreational Impact Avoidance and Mitigation Strategy (GIRAMS) will need to be incorporated in the policies of the Local Plan and supporting documents, once these are finalised.
To summarise our response briefly, we broadly welcome the progress and development of aspects of the Local Plan and supporting documents to date, though Natural England is not yet satisfied that the relevant Plan polices will provide sufficient mitigation to ensure that there will be no adverse impacts to designated sites alone, and in-combination, through changes in water quality and resources and in regard to recreational disturbance, and to demonstrate that policies are sustainable.