Comment
Stage C Evidence Base
Representation ID: 22061
Received: 16/03/2020
Respondent: Norfolk Wildlife Trust
Habitats Regulations Assessment (HRA)
There is a legal requirement for the plan to be accompanied by a HRA demonstrating that the plan will not result in any adverse effects on European Sites before the plan can be adopted. Our detailed comments are given below, but we wish to highlight our overall concerns with the conclusions drawn by the draft HRA issued at this stage. The conclusions that adverse effects on the River Wensum SAC and the suite of Broads European Sites appear to mostly depend on an evidence base being produced by third parties that is not yet complete. We therefore disagree with the overall conclusion of the draft HRA that there would be no adverse effects on European Sites either alone or in combination with other plans and projects. This issue will need resolving prior to publication of the submission version of the plan. We request a direct meeting with the Council and their consultants, ideally alongside other nature conservation bodies, as soon as possible after the consultation in order to discuss the outstanding actions required to ensure the HRA is completed satisfactorily in time for the submission stage.
Thank you for consulting Norfolk Wildlife Trust on the draft Greater Norwich Local Plan. We have attempted to comment wherever possible in response to the questions set out in the consultation, but have a number of comments which cover multiple policies or supporting documents and so have compiled our comments in this letter.
See attached for full submission