Comment

Representation ID: 22069

Received: 16/03/2020

Respondent: Norfolk Wildlife Trust

Appendix 3 Monitoring
The monitoring framework is intended to identify how well the local plan is implemented, but we believe that the indicators chosen for the natural environment need to be changed, as those currently selected do not relate to the planning system.
Indicator GNLP18 measures the percentage of SSSIs in favourable condition, whilst indicator GNLP19 measures the percentage of County Wildlife Sites in positive conservation management. However, these variables are unrelated to the local plan and planning permissions and we recommend they are reviewed. We support the inclusion of GNLP20 which gives an indication of the proportion of cases approved against formal advice. However, given that NWT are not able to comment on all cases where there are biodiversity impacts, whilst this indicator could act as an index of development pressures on wildlife sites, it is incomplete. We recommend the addition of an additional target which records the areas of nature conservation sites (as listed in Table 4 of the plan) and non-designated Priority Habitats including ancient woodland (as defined by the NERC Act 2016) lost to development. As one of the plan objectives is to protect and enhance the natural environment, we recommend the target is set at zero loss.
In addition, in anticipation of the mandatory biodiversity net gain requirement included in the current Environment Bill, we recommend that an additional target is added to measure the amount of net gain delivered, as per the DEFRA Biodiversity Metric. The related aspiration in the Environment Bill to create a Nature Recovery Network also has clear overlaps with the requirement for development to provide biodiversity net gain.