Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21835
Received: 16/03/2020
Respondent: Natural England
There are no specific references to GI in the supporting text or policy and we advise that this needs to change with due recognition and importance given. GI is essential for the delivery of sustainable development. Strategic infrastructure has been identified to meet economic and social imperatives but fails to identify any strategic infrastructure to meet environmental requirements. In the absence of the identification of strategic GI it is unclear how the Plan will deliver sustainable growth, or address the impacts of climate change. This needs to be addressed under the heading of ‘Strategic Green Infrastructure’ both in the supporting text and within the policy wording.
The findings of the WSC may need to be reflected in the policy and supporting text.
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.