Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 22191

Received: 16/03/2020

Respondent: Environment Agency (Eastern Region)

Representation Summary:

The definition of green infrastructure in the Glossary seems to imply that the plan is not taking the broader definition to include natural habitats into account. The plan must specifically address mitigation and compensation for loss of natural habitats (this is also relevant to Policy 7.2). We would like to see a target % of green infrastructure to be provided within a development.
Site Allocations
The quality of the water from new developments is our primary concern about those near chalk streams. Chalk streams are naturally low in nutrients and have good water quality. There are risks due to car washing, use of herbicides in gardens, run off from roads contaminated with salt and chemicals from cars. The plan needs to ensure that the provision of SuDS is appropriate and follows design guidance. New developments must undertake a WFD compliance assessment to ensure that they do not cause and deterioration and do not compromise our ability to meet Good WFD status.
The plan should also identify areas (outside of land allocations) where small developments would need to rely of de-minimus abstraction 20m3 per day (where there is no potable water supply). This kind of development would have negative impacts on an area already under water stress so these areas should be identified and development restricted.

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