Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21830
Received: 16/03/2020
Respondent: Natural England
For the Local Plan to deliver actual sustainable development and significantly address climate change, the vision needs to be better balanced. Otherwise, the vision as set out in (109) - (111) appears to be heavily focussed on growth at the expense of the other two pillars of sustainable development.
In our response (dated 21 March 2018 ref:235617) to a previous consultation on the Local Plan, we considered that the vision would be improved by the inclusion of the following words under (110):
‘… and an a protected and enhanced environment’.
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We maintain that this wording is important to include as it sets the tone for the Local Plan and signals the commitment of the local authorities to safeguard their natural assets.
We also consider that under (110) the text should be amended as follows:
‘Growth will make the best of Greater Norwich’s distinct built, natural and historic assets whilst protecting and enhancing them.’
In relation to the Plan’s objectives, Natural England expects GI to feature prominently in the objectives as it has a crucial role in delivering the following objectives: economy, communities, homes, infrastructure and environment and as highlighted in our comments to (101) above. We strongly recommend that the text is amended to reference GI under each of the objective headings (112) – (134) as well as in the wording of these objectives as listed under (135).
We emphasised the role and importance of GI in the new Local Plan in our previous consultation response and would like to re-emphasise its importance in this response. Unless GI is given central prominence in the policies, which need to clearly explain in detail how and where GI will be delivered and the timescale for it, the Plan is unlikely to deliver sustainable development, or adaptation to the impacts of climate change, across the Greater Norwich area.
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.