Comment

Representation ID: 22067

Received: 16/03/2020

Respondent: Norfolk Wildlife Trust

Policy 4 – Strategic Infrastructure
Whilst we recognise the requirement in the NPPF for the GNLP to make provision for strategic infrastructure, it is unclear from the draft plan which elements are reliant on the provision of strategic infrastructure and are therefore at risk of delivery should the infrastructure projects fail to be delivered. We note the potential significant impacts on wildlife from proposed new road infrastructure and the demands new development will place on water supply and treatment capacity. Given the proximity of these infrastructure concerns to European Sites, and the apparent presumption by the plan that they can be delivered without adverse effects, there is a risk to delivery of the plan if the infrastructure projects are unable to demonstrate that they can avoid these adverse effects and gain consent.

We seek further clarification from the Council regarding the risks to delivery of the plan if infrastructure proposals are not able to be delivered. We note that the baseline ecological surveys for the Western Link Road are still being carried out, whilst the water cycle and visitor pressure studies which are needed to inform the legality of the plan via the HRA are still in production, with their completion dates unknown. Our concerns are given in more detail in our comments on the HRA below, given the legal need for the plan to demonstrate that adverse effects on European Sites will be avoided.