Object

Representation ID: 24420

Received: 22/03/2021

Respondent: Mr Andrew Cawdron

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

The Glossary definition given in the Reg. 19 documents on page 131 is "A term mostly derived from the 1987 Brundtland Report. Interpretation varies, but typically the term means meeting economic and social goals without undermining the environment, as well as meeting needs of the present without compromising the environment for future generations. In 2015 the United Nations agreed 17 Sustainable Development Goals to be reached by 2030. The UK is amongst the countries leading the delivery of the Sustainable Development Goals."
Also note the context of the more up to date 2019 NPPF Section 15 requires that policies and decisions should contribute to and enhance the natural and local environment.
Changes to the NPPF in the current Government public consultation go further in proposing changes to paragraph 11a) that "all plans should promote a sustainable pattern of development that seeks to: meet the development needs of their area; align growth and infrastructure; improve the environment; mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects" replacing the emphasis in the current NPPF that plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change.
Reg. 19 Policy 3 places environmental protection and enhancement onto individual development proposals, but adds an overriding dominant factor of benefits and minimising harm, (without explanation of what is considered to be a benefit).
There are two specific policies in the GNLP relating to enhancement of the environment namely:
• At least 10% net biodiversity gain (on or off site).
• Addressing the potential detrimental impact of visitor pressure caused by residents on sites protected under the Habitats Regulations, "by the payment of a contribution towards the cost of mitigation measures at the protected sites (as determined under the Norfolk Green infrastructure and Recreational Impact Avoidance and Mitigation Strategy, plus an allowance for inflation); and the provision or enhancement of adequate green infrastructure, either on the development site or nearby, to provide for the informal recreational needs of the residents as an alternative to visiting the protected sites. This will equate to a minimum of 2 hectares per 1,000 population and will reflect Natural England's Accessible Natural Greenspace Standard.
The above reference to Natural England Accessible Natural Greenspace Standard does not mention the remainder of the quoted section namely;
• no person should live more than 300m from their nearest area of natural green space;
• there should be at least one accessible 20ha site within 2km from home;
• there should be one accessible 100ha site within 5km;
• there should be one accessible 500ha site within 10km.
The purpose of this model is to guide local authorities in identifying the current level of provision of accessible natural green space and to assist with the setting of local standards and targets. The GNLP fails in its assessment of how the current environment equates to these standards nor provides any plans for any rebalance necessary.
The government study in 20 I I of areas noted the classification of the three districts comprising Greater Norwich as: Norwich - Urban: Broadland - Urban with significantly rural: South Norfolk – Mainly rural
The present GNLP collects the different geographical classifications into a single entity with a single sustainability policy which risks losing much of the rural classification . The sustainability of the environment is inadequate in the plan in consideration of the diverse nature across the 3 districts and the equal standing given to the environment in the NPPF to those of economic and social objectives.
Concerning biodiversity the study states "Biodiversity Net Gain (BNG) will still require the application of the mitigation hierarchy to avoid, mitigate or compensate for biodiversity losses on any sites within the GNLP. BNG will operate in addition to these approaches, with the aim of ensuring that definite improvements to biodiversity are delivered. "
Avoidance of biodiversity harm should be the principle consideration before deciding whether mitigation is acceptable. Clarity is required in the GNLP that biodiversity net gain will be implemented in the locality of and appropriate to each development. It is unacceptable to degrade the environment of any area on the assumption that another will be improved as compensation. Clarity is also required as to the continued maintenance or management of these green space areas.