Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21832
Received: 16/03/2020
Respondent: Natural England
The current wording of the policy needs to be strengthened with regard to the environment and the delivery of GI. Currently it is rather vague and weak with regard to the essential role that quality GI must play if sustainable development is to be delivered under the Plan and meet the needs and aims as set out in the accompanying text under (144). The policy needs to cross reference Policy 3 in order to provide a strong and clear steer of what will be required to deliver the growth strategy whilst protecting and enhancing the area’s natural environmental assets, and to make the Plan sound. We recommend that the wording of the policy needs to be amended as follows (or a similar form of wording used):
“Sustainable development and inclusive growth are supported by…
supporting infrastructure will be provided in line with policies 2, 3 and 4;
environmental protection and enhancement measures including further improvements to the green infrastructure network will be delivered in line with policy 3.”
and:
“INFRASTRUCTURE
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The sustainable growth strategy will be supported by improvements to the transport system, green infrastructure and services. Improvements to existing green infrastructure and the creation of new green infrastructure will be delivered in line with policy 3.”
Whist we welcome recognition that new development must be supported by additional infrastructure of all kinds, in terms of GI, the reference to Appendix 1 is disappointing, given the complete absence of GI being mentioned in Appendix 1. The appendix is based on the findings of the undated Greater Norwich Local Plan Infrastructure Needs Report (GNLPINR). The GNLPINR make very limited reference to the provision of GI via a large scale map which shows strategic GI corridors and contains two sentences.
We strongly recommend that references to GI throughout the Plan should be made instead to the Greater Norwich Infrastructure Plan (dated July 2019). This document refers to GI in many sections, and in Appendix A – Infrastructure Frameworks includes a detailed list of the GI projects that will be delivered under the current Joint Core Strategy (JCS), and presumably rolled forward into the new Plan. Clearly, it will need to be updated due to the new development being proposed under this consultation. However, more detailed information about the quality and quantity of GI together with where on the ground it will be delivered needs to be included in the Plan.
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.