Comment

Representation ID: 22186

Received: 16/03/2020

Respondent: Environment Agency (Eastern Region)

We would like to see a target percentage for green infrastructure within the development parcel. Biodiversity Net Gain doesn’t see, to be referenced in the table. In reference to point 9, water, in the key issues by policy 2 table on pages 57 and 58, this has not recognised the challenge ahead in finding water for developments and simply says that the cost of water efficiency measures is negligible and can be easily achieved. This is not necessarily the case as the water company has a duty to find water. However, there is no water available and there is a significant challenge in sourcing water for the growing population and new developments.
There is real opportunity to use the Net Gain principal to expand existing habitats, create new wildlife corridors though planting belts of woodland and hedgerows, wetland creation, expanding the buffers around riparian corridors etc. The kind of measures that might be required in order to address climate change will be needed within the development sites as well as over a much bigger scale within the whole plan area.
We welcome that the plan supports “a catchment approach to water management and using sustainable drainage”. It would be good to build on this in other sections referring to the catchment based approach and Broadland Catchment Partnership highlighting catchment plans and areas identified by the partnership for habitat enhancements in accordance with paragraph 174 of the NPPF.
We support the use of infiltration features and SuDS to reduce flood risk, but they should consider pollution risk to groundwater and surface water.' and make reference to our position statements G1 to G1 and G9-13. https://www.gov.uk/government/publications/groundwater-protection-position-statements

The Natural Environment
We would like to see a greater emphasis here on providing green infrastructure within developments with a specific percentage green infrastructure target. This will help reduce recreational dog walking impacts on natural habitats as well as enabling and supporting healthy lifestyles through local provision of green space for exercise and recreation with nature. The provision of green infrastructure within developments will help to increase infiltration and reduce runoff contaminated with pollutants entering our rivers.
Green Infrastructure Corridors (page 67)
We welcome that most rivers and their tributaries have been recognised as green infrastructure/habitat corridors and support any opportunities to improve habitats within the corridors.
However, the green lines do not reflect the mosaic of habitats within them and where there are opportunities to revert agricultural land to natural habitats to mitigate against and compensate for the impacts of development. The plan should take a more strategic approach in order to create a coherent ecological network. The plan would benefit by being taken a step further by identifying which broad habitat types will be lost by developing the land allocated in the plan and identify where the compensation habitat could be created or through what mechanism is could be created.