Comment

Representation ID: 23091

Received: 16/03/2020

Respondent: Norfolk Wildlife Trust

Thank you for consulting Norfolk Wildlife Trust on the draft Greater Norwich Local Plan. We have attempted to comment wherever possible in response to the questions set out in the consultation, but have a number of comments which cover multiple policies or supporting documents and so have compiled our comments in this letter.

Our key overarching comments are given below, followed by specific responses to policy questions and supporting documents.

Future Impacts of Climate Change on Wildlife and Zero Carbon targets
Evidence is clear that the effects of climate change on Norfolk’s wildlife will be significant, in addition to the pressures it already faces from habitat loss, fragmentation, disturbance and invasive species. A recent paper highlighted the many species likely to be lost from Norfolk in response to a 2 degree temperature rise. Therefore, to avoid committing Norfolk to further unnecessary wildlife losses, and to safeguard natural areas critical to the storage and sequestration of carbon in the future, we strongly recommend that the plan takes every opportunity possible to help reach national carbon neutrality goals as soon as possible, locking in gains for climate change mitigation and adaptation in all new development. This should include zero carbon targets for new housing, in line with the examples set by Reading Borough Council in policy H5 of their recently adopted Local Plan.

Urban Greening
We strongly recommend the inclusion of a mandatory requirement for development to include green design features such as green roofs, walls and sustainable drainage. Such measures will contribute to a wide range of targets set out in Policy 2, improving the resilience of the built environment to climate change, improving building energy efficiency through improved insultation, reducing the urban heat island effect and reducing rates of rain run-off that contribute to flooding, in addition to the benefits to wildlife that this will provide by enhancing the ability of the urban environment to provide habitats and stepping stones for wildlife to move in response to climate change. Southampton City Council City Centre Action Plan and the London Plan show examples of successful inclusion of such policies in other city plans. For further information on the benefits or urban greening policies, see reports produced for the London Plan and by the Town & Country Planning Association on the benefits of urban greening policies.

Wildlife Site Safeguarding Consistency
We have not been able to identify any allocations which would result in the direct loss of County Wildlife Sites (CWS), although a few have CWS within their site boundaries with draft policies to safeguard them and manage them as green infrastructure. We note that for the remainder of the proposed allocations in proximity to wildlife sites (SAC, SPA, Ramsar, SSSI, CWS, Ancient Woodland, Local Nature Reserves, Protected Road Verges), some make reference to adjacent CWS and support safeguarding from indirect impacts and buffering with new green infrastructure, but not all. We recommend that all allocations should be reviewed against these criteria in order to ensure that appropriate policy wording can be included to safeguard them from damaging development. This will help ensure compliance with targets in the plan to ensure no losses and net gains for wildlife from development.

Biodiversity Net Gain and Nature Recovery Networks
The Environment Bill currently progressing through Parliament includes provisions for mandatory Biodiversity Net Gain (BNG) for all new development and the creation of Nature Recovery Networks (NRNs). A metric for the measuring of BNG has been consulted on extensively by DEFRA and is already available for use. Natural England have recently released advice on the establishment of NRNs, which clearly highlights the important role the planning system (and in particular the delivery of BNG) needs to play in the successful creation and maintenance of NRNs. Whilst we recognise that the Environment Bill has not yet been passed, it is highly likely that it will be passed before the next consultation stage of the GNLP. Therefore we recommend that detailed consideration is given to how the GNLP will help deliver measurable biodiversity net gain in all new development and ensure that the development and green infrastructure it promotes will help towards the delivery of an effective NRN for Norfolk. Given our expertise with landscape scale nature conservation projects, the Trust would be happy to discuss this in further detail with the GNLP team once the Environment Bill has passed and the requirements are clearer.