Comment
Stage C Evidence Base
Representation ID: 21839
Received: 16/03/2020
Respondent: Natural England
Sustainability Appraisal and Strategic Environmental Assessment Report
Natural England welcomes the production of the latest iteration of the above document, dated January 2020, and prepared by Lepus Consulting, and in the following comments below it shall be referred to as the Sustainability Appraisal (SA).
We previously commented on the scoping of the SA in our response dated 12 August 2016 (our ref: 1887410) and on the interim SA in our response (dated 21 March 2018; our ref 235617) to the GNLP growth options and site proposals consultation. Whilst we recognise that some of our advice has been reflected in the latest version of the SA, we have the following comments to make:
See Attachment
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.