Comment

Representation ID: 22187

Received: 16/03/2020

Respondent: Environment Agency (Eastern Region)

This policy contains a statement which states “development should deliver biodiversity net gain wherever possible”. Once the Environment Act has become legislation, this statement must be strengthened.
The policy around the natural environment must be clarified as it seems muddled. There should be separate statements for accessible green space (which could be integrated with biodiversity enhancements) and natural habitats (whose conservation value may be compromised by full public access). Overall, the importance of the natural environment in its own right needs to be recognised.
Paragraph 197 states that the Environment Bill is currently being considered in parliament. However, government policy has now made net gain mandatory and this should therefore be updated within the plan.
In regards to paragraph 191 - The creation of Country Parks on areas already identified as priority habitat under the NERC (for example Bawburgh lakes and Horsford) could bring both negative and positive impacts on these habitats. Sensitive management could benefit some species, however the impacts of increased visitor pressure, disturbance from dogs and so on, will have to be carefully assessed to ensure that there is no deterioration in the quality of these habitats.
We would encourage the plan to incorporate new areas that are currently of limited value to wildlife (agricultural land) and create new habitats and parks in these locations. These areas could be strategically planned to increase the connectivity of existing habitats. On suitable agricultural land, the creation of new parks would bring immediate unquestionable net gain and could improve habitat connectivity as well as improving the green infrastructure network.
It is disappointing that the does not include any reference to environmental legislation. There needs to be reference in this section to WFD (outlining key objectives, no deterioration & improvement in waterbody status) and habitats directive which is particularly important to this district. For the policy itself, we suggest adding the following text: "...Key elements of the natural environment include valued landscapes, biodiversity including priority habitats, networks and species, geodiversity, a high quality and plentiful water environment, high quality agricultural land and soils."
The policy should also include a paragraph around encouraging redevelopment of brownfield sites, with appropriate risk assessment to protect the water environment. This policy discusses "enhances" but again does not reference WFD which is a key piece of legislation supporting and setting specific targets for enhancement. This needs amending.