Comment

Representation ID: 22458

Received: 16/03/2020

Respondent: Gladman Developments

2.2 Policy 3: Environmental Protection and Enhancement (Question 21)
2.2.1 Gladman has some concern with the proposed approach taken by Policy 3 towards development
proposals within Green Infrastructure Corridors illustrated in Map 8 of the draft Plan. Map 8
represents a high-level assessment of Green Infrastructure across the County with limited regard to
more detailed site data and functionality. For example, Gladman’s land interest at Long Lane,
Costessey is shown to be included within the Green Infrastructure Corridor which aligns with the
western edge of Norwich. Despite this designation, there have been planning applications
approved within the identified Green Infrastructure Corridors, including the land to the north of the
Site at Lodge Farm.
2.2.2 Taking this into account, it is unclear on what basis Policy 3 seeks to protect the Green Infrastructure
Corridors identified in Map 8 given that in some cases evidence of these corridors on the ground is
limited. Gladman considers that the focus of Policy 3 in relation to Green Infrastructure should be
to secure environmental benefits at the planning application stage to enhance the quality and extent of the corridors with the aim of securing the functionality and extent of the Green
Infrastructure corridors shown on Map 8 in the longer term. In this sense, contributions towards
Green Infrastructure corridors made by development proposals in the area should be considered a
planning benefit.
2.2.3 Should wording on protection of Green Infrastructure corridors be retained in the policy, Gladman
considers that further evidence is needed to set out what elements of the Green Infrastructure
corridors need to be protected and for what reason. It should also be set to a greater level of detail
what is meant by the term “effective management of development in accordance with the policies
of the development plan”. Gladman would be resistant to a policy approach which would refuse
development affecting a Green Infrastructure corridor where evidence shows limited
environmental site value and/or the proposed development could lead to enhancements in Green
Infrastructure.