Comment

Representation ID: 22464

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 broad brushed 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 Norwich Common, Wymondham is shown to be partially included within the Green Infrastructure corridor aligning to the A11, despite the Site showing limited evidence of ecological value as shown by technical reports produced as part of the current planning application.
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, with areas within these which important to ecological conservation subject to protection through formal designation.
2.2.3 Gladman consider that the focus of Policy 3 in relation to Green Infrastructure should be to secure environmental benefits at the planning application stage which are important to the enhancement of the quality and extent of Green Infrastructure corridors. This is in 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.
2.2.4 Should wording on protection of Green Infrastructure corridors be retained in the policy, Gladman consider that further evidence is needed to set out what elements of the Green Infrastructure corridors need to be protected and for what reason. The meaning of “effective management of development in accordance with the policies of the development plan” in terms of impacts for planning applications and decision making should also be clarified. 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 to the integrity and value of Green Infrastructure.