Object
Publication
Representation ID: 24447
Received: 22/04/2021
Respondent: Trustees of First Viscount Mackintosh of Halifax and Trustees of CM Watt Residual Trust
Agent: La Ronde Wright
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Policy 3 is a standard policy that is adopted by most LPA's regarding the need to provide biodiversity enhancements as part of an overall ambition for conserving and enhancing the natural environment. This is a noted sentiment, however reality is that a large number of developments fail to provide meaningful or significant benefits to the natural environment, due to limited opportunities for providing Public Open Space and landscaped areas on site. An updated evidence base is needed and a new approach should be considered, which results in the dedicated allocation of significant amounts of land for enhancements, that can help mitigate carbon emissions and other impacts of development. Looking at the proposed allocations for development, the GNLP proposes a wealth of residential development that ultimately will drain the existing POS provision within the administrative area, and new POS will likely not address the biodiversity implications of development, due to its sporadic, and ad hoc placement within wider developments. As such, it is considered that this blanket approach of stating that net gain will be provided on-site or off-site is unlikely to be effective, and instead a new strategy based on an alternative approach as highlighted by paragraph 35 of the NPPF should be sought. In its current form, the plan is unsound due to this unjustified and ineffective strategy that has not been positively prepared.
Given the dire need for preserving and enhancing the natural environment, it is the view that large amounts of natural land should be allocated to provide Public Open Space, at a suitable scale that would supplement existing development, ensuring the whole Plan provides biodiversity net gains and ecological enhancements. For example, the land at Racecourse Community Park is an existing Parkland that is underused, but would benefit from additional revenue to facilitate a vast program of works to boost the biodiversity and ecological value of the land once the planned interventions along its boundaries take place. Namely, the extension to the Thickthorn Park & Ride and the A47/A11 Highways England link road. The opening up the park to the public alongside with the limited built development proposed at site GNLP0177-B would result in a range of benefits to economic, social and community infrastructure and contribute positively to the natural environment.
The allocation of this essential green infrastructure and the three relatively small sites which would secure its long-term management and maintenance within GNLP0177-B would protect it for present and future generations and reduce the deterioration of the landscape likely to result from the planned interventions along its boundaries.
As can be seen through the recent COVID-19 pandemic, the importance of accessible public open space within close proximity to homes and places of work is vital to maintaining a healthy lifestyle.
Given the existing infrastructure improvements and the adjacent Park and Ride and its planned extension this site could provide not only large-scale community space for the residents of both Hethersett and Cringleford, but would supplement the public open space provision of other allocations and developments nearby.
Please find attached representations in relation to the GNLP Regulation 19 consultation with regard to site GNLP0177-B. These representations are submitted by Le Ronde Wright Limited on behalf of the Trustees of the site.
This representation relates to Policy 3, 5, 6 and the SA. For more details please view the summaries.