Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 23149
Received: 16/03/2020
Respondent: Natural England
We warmly welcome and support this policy.
Under (3) we consider the provision of accessible GI for recreational uses should be included within the policy. This is necessary to help mitigate the impacts of additional recreational pressure from new housing development on designated sites.
Under (9) we endorse the adoption of the higher standard for water efficiency under the Building Regulations, which is also supported by evidence in the WCS. Reference to retrofitting existing buildings with water efficiency measures has also been as identified as essential in the WCS in terms of managing water demand. We suggest it would be appropriate to include some wording in this policy which recognises this need, and supports its implementation should Government adopt this approach in future.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
We support Broadland District, Norwich City and South Norfolk Councils’ preparation of a joint Local Plan to ensure a consistent approach to planning across the Greater Norwich area, with policies aligned with the revised National Planning Policy Framework (NPPF).
We have made detailed comments in this letter in relation to the following Greater Norwich Local Plan (GNLP) consultation documents:
Draft Local Plan – Part 1 The Strategy
Draft Sites Document
Habitats Regulations Assessment of GNLP, December 2019
Sustainability Appraisal and Strategic Environmental Assessment, January 2020
Natural England acknowledges that the findings of supporting documents including the draft Greater Norwich Water Cycle Study (WCS) (AECOM 2019) and the emerging Green Infrastructure and Recreational Impact Avoidance and Mitigation Strategy (GIRAMS) will need to be incorporated in the policies of the Local Plan and supporting documents, once these are finalised.
To summarise our response briefly, we broadly welcome the progress and development of aspects of the Local Plan and supporting documents to date, though Natural England is not yet satisfied that the relevant Plan polices will provide sufficient mitigation to ensure that there will be no adverse impacts to designated sites alone, and in-combination, through changes in water quality and resources and in regard to recreational disturbance, and to demonstrate that policies are sustainable.