Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21837
Received: 16/03/2020
Respondent: Natural England
Natural England has not commented on the individual preferred sites for new allocation nor on the reasonable alternative sites identified, due to the number of sites involved and limitations on our resources.
We previously responded to a consultation on new, revised and small sites (our letter dated 14 December 2018; our ref: 262820). Our advice made in that response remains relevant to this current consultation on the selection and allocation of sites under the GNLP, and needs to be considered fully.
Similarly, the advice provided in this letter regarding various Plan policies and the HRA needs to be incorporated into the policy and supporting text of each relevant individual site allocation policy, making it clear that the allocation will only be deliverable if a project level HRA can demonstrate no adverse effects. Any mitigation measures identified through the HRA or the emerging GIRAMS need to be included too.
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.