Object

Representation ID: 21834

Received: 16/03/2020

Respondent: Natural England

Natural England objects to the current wording of Policy 3 and considers that the policy and supporting text are inadequate to protect, maintain, restore and enhance the natural environmental assets of the area and the benefits arising from these for residents, workers and visitors. It will not ensure the delivery of GI of sufficient quality and quantity in the right locations, nor help the Plan to meet the sustainability criteria or adapt to climate change. It contains too much uncertainty and needs to explain the hierarchies of site protection and mitigation.
The natural environmental assets found in the Greater Norwich area, and adjoining it, provide immense benefits that deliver across all three pillars of sustainability. In terms of benefits to the economy and society alone, these would run into tens of millions of pounds if they were calculated over the lifetime of the Plan.
We strongly recommend that Policy 3 and the supporting text are substantially amended and expanded. The 175 words assigned to the current natural environment section of Policy 3 cannot do justice to what is required for the Greater Norwich area and surroundings. Much of the wording and maps in Policy 1: Addressing climate change and protecting environmental assets in the current Joint Core Strategy (2011) remains valid and relevant. Parts of it could form the basis of a new Policy 3, which needs to cover measures in relation to climate change adaptation, halting and reversing the loss of biodiversity in relation to the Government’s 25 year Environment Plan and Nature Recovery Networks, biodiversity net gain, recreational disturbance, suitable alternative greenspace (SANGS) and GI networks.
We also suggest looking at East Suffolk Council’s Local Plan Final Draft and Policy SCLP 10.1: Biodiversity and Geodiversity and the supporting text in general, for the approach that we endorse (https://www.eastsuffolk.gov.uk/assets/Planning/Suffolk-Coastal-Local-Plan/Final-Draft-Local-Plan/Final-Draft-Local-Plan.pdf).
GI references in the Plan repeatedly refer to the strategic GI network as set out on the (basic) Map 8 and very little else. The Local Plan needs to provide a strategic document that sets out what the GI network will look like on the ground, how and where it will be delivered and the timescale, together with detailed information about the existing GI network and how it, too, will be protected, enhanced or expand. At this stage of the plan process there needs to be far more detail provided to be certain that it will be delivered, and for the HRA to be able to assess in relation to the mitigation measures that have been identified.
Natural England, together with other partners, would very much like to work with the local authorities in revising and expanding Policy 3 to ensure it is comprehensive and robust.