Question 21: Do you support, object or have any comments relating to the approach to the natural environment?
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 19828
Received: 03/02/2020
Respondent: Mr David Hooker
The Green Infrastructure corridors clearly omit the Tud River Valley. The document makes no mention of the requirements for a corridor to be included. By implication corridors that are not included will not be protected. This seems unreasonable and the situation should be addressed.
The Green Infrastructure corridors clearly omit the Tud River Valley. The document makes no mention of the requirements for a corridor to be included. By implication corridors that are not included will not be protected. This seems unreasonable and the situation should be addressed.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 19861
Received: 07/02/2020
Respondent: Dr Matthew Tomlinson
The yare valley is a key natural resource for the residents of Norwich and a vital green corridor. It has important recreational and biodiversity value. Allowing building on this and immediately neighbouring land would be a great loss to the landscape, any effort to tackle the challenge of climate change and the green spaces of Norwich.
The yare valley is a key natural resource for the residents of Norwich and a vital green corridor. It has important recreational and biodiversity value. Allowing building on this and immediately neighbouring land would be a great loss to the landscape, any effort to tackle the challenge of climate change and the green spaces of Norwich.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 20058
Received: 23/02/2020
Respondent: Mr Norman Castleton
Green Spaces & Woodland
The environmental proposals cannot be taken seriously when the green space of the former Hellesdon Golf Course will be concreted over with 1000 houses. Neither are the proposals to build on land within the area of Thorpe Woods & the travesty that is the NDR - £60 million overspend & the destruction of flora and the failed tree planting. To think that that there are proposals for a Western Link and the some destructive mode is beyond belief.
Green Spaces & Woodland
The environmental proposals cannot be taken seriously when the green space of the former Hellesdon Golf Course will be concreted over with 1000 houses. Neither are the proposals to build on land within the area of Thorpe Woods & the travesty that is the NDR - £60 million overspend & the destruction of flora and the failed tree planting. To think that that there are proposals for a Western Link and the some destructive mode is beyond belief.
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 20223
Received: 02/03/2020
Respondent: Nicola Harrison
Don't build the Norwich Western Link. It cuts through a Barbastelle bat super colony these are nationally rare bats. We should cherish and protect them in Norfolk. The A47 planned 'improvements' will also damage and cut through natural habitat and cause pollution. The R. Tud needs protecting this road scheme will increase dependancy on cars. The two junctions planned will spoil the landscape and are not appropriate for a rural setting. Norfolk is beautiful because it doesn't have roads like this please keep it that way.
Don't build the Norwich Western Link. It cuts through a Barbastelle bat super colony these are nationally rare bats. We should cherish and protect them in Norfolk. The A47 planned 'improvements' will also damage and cut through natural habitat and cause pollution. The R. Tud needs protecting this road scheme will increase dependancy on cars. The two junctions planned will spoil the landscape and are not appropriate for a rural setting. Norfolk is beautiful because it doesn't have roads like this please keep it that way.
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 20350
Received: 05/03/2020
Respondent: Brockdish & Thorpe Abbotts Parish Council
We support the CPRE view that this policy is far too narrow. It is entirely reactive. The GNLP should contain pro-active measures to improve the environment and counter-act climate change. As an example the Government wants to plant millions of trees so the GNLP should take a lead on where and how this should take place and commit a budget to it.
We support the CPRE view that this policy is far too narrow. It is entirely reactive. The GNLP should contain pro-active measures to improve the environment and counter-act climate change. As an example the Government wants to plant millions of trees so the GNLP should take a lead on where and how this should take place and commit a budget to it.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 20619
Received: 11/03/2020
Respondent: Mrs Janet Skidmore
Agent: Carter Jonas LLP
It should be noted that national guidance expects planning decisions to contribute towards and enhance the natural environment, and to secure measurable net gains for biodiversity – see Paragraphs 170 and 174 of the NPPF. It should be acknowledged that development can deliver ecological enhancements and net biodiversity gains. The promoted development at land south of Gonville Hall would include ecological enhancements.
It should be noted that national guidance expects planning decisions to contribute towards and enhance the natural environment, and to secure measurable net gains for biodiversity – see Paragraphs 170 and 174 of the NPPF. It should be acknowledged that development can deliver ecological enhancements and net biodiversity gains. The promoted development at land south of Gonville Hall would include ecological enhancements.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 20641
Received: 11/03/2020
Respondent: Noble Foods Ltd
Agent: Carter Jonas LLP
It should be noted that national guidance expects planning decisions to contribute towards and enhance the natural environment, and to secure measurable net gains for biodiversity – see Paragraphs 170 and 174 of the NPPF. It should be acknowledged that development can deliver ecological enhancements and net biodiversity gains. The promoted development at land at Fengate Farm in Marsham would include ecological enhancements.
It should be noted that national guidance expects planning decisions to contribute towards and enhance the natural environment, and to secure measurable net gains for biodiversity – see Paragraphs 170 and 174 of the NPPF. It should be acknowledged that development can deliver ecological enhancements and net biodiversity gains. The promoted development at land at Fengate Farm in Marsham would include ecological enhancements.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 20674
Received: 11/03/2020
Respondent: CPRE Norfolk
CPRE Norfolk does not wish to summarise what are a series of important points into 100 words or less. The consultation should welcome thorough responses, and not imply that only shorter summaries will be reported.
CPRE Norfolk supports further ‘development of a multi-functional green infrastructure network’. However, we have major concerns about how biodiversity net gain will be evaluated, assessed and measured, although it is recognised that at this point it is unclear as to what the legal requirements of this policy will be given the current progress of the Environment Bill.
Paragraphs 183 and 184 talk about the great weight placed on protecting the natural environment in Greater Norwich, but then there are no clear details on how this will be achieved. Provision of a Green Belt on a ‘green wedges’ model would go some way to addressing this.
This draft Plan takes a very narrow view on the NPPF and 25-Year Plan on policies for the natural environment, namely that strategy, aims and policies are restricted to considering only gain as seen through the prism of development. There is a duty to cooperate between Councils, and that should automatically happen. While implementation may be less direct, there should be a wider strategic vision that does support policies of the NNPF. CPRE Norfolk has a proposal for a Nature Recovery Network from the North Norfolk Coast to the east coast (including parts of the Broadland DC area), by the enhancement of the ecological network provided by our river systems, and supported by the environmental land management scheme. This includes a detailed planning and land management document for landscapes and wildlife relating to a Nature Recovery Network, which also include an AONB extension to the Norfolk Coast AONB into the full catchments of the twin North Norfolk rivers Glaven and Stiffkey. This could be added to Policy 3 as a means by which there would be further protection and enhancement of the Natural Environment.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 20748
Received: 12/03/2020
Respondent: Hempnall Parish Council
Paragraphs 183 and 184 talk about the great weight placed on protecting the natural environment in Greater Norwich, but then there are no clear details on how this will be achieved. Provision of a Green Belt would go some way to addressing this.
Paragraphs 183 and 184 talk about the great weight placed on protecting the natural environment in Greater Norwich, but then there are no clear details on how this will be achieved. Provision of a Green Belt would go some way to addressing this.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 20973
Received: 14/03/2020
Respondent: Mr Andrew Cawdron
It is good to see good quality agricultural land as being one of the areas for active protection. It hasn't been upheld with Growth Triangle Planning. Clause 183 actually asks for development to result in biodiversity net gain, but it's not a Policy Requirement and should be. Delete the phrase "wherever possible" As for "SANGS", that is a disgraceful option to have in place. So far environmental considerations have singularly failed to carry equal weight to economics or vanity projects like the Western Link Road (not yet consented or applied for) which is an environmental catastrophe in the making.
It is good to see good quality agricultural land as being one of the areas for active protection. It hasn't been upheld with Growth Triangle Planning. Clause 183 actually asks for development to result in biodiversity net gain, but it's not a Policy Requirement and should be. Delete the phrase "wherever possible" As for "SANGS", that is a disgraceful option to have in place. So far environmental considerations have singularly failed to carry equal weight to economics or vanity projects like the Western Link Road (not yet consented or applied for) which is an environmental catastrophe in the making.
Support
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21105
Received: 15/03/2020
Respondent: Saving Swainsthorpe Campaign
In the CPRE submission they refer to concerns relating to how bio-diversity will be assessed evaluated and measured - whilst we broadly support the approach set out in this draft we remain concerned about how the balance between the environment and development will be assessed and who will evaluate that process.
In the CPRE submission they refer to concerns relating to how bio-diversity will be assessed evaluated and measured - whilst we broadly support the approach set out in this draft we remain concerned about how the balance between the environment and development will be assessed and who will evaluate that process.
Support
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21152
Received: 15/03/2020
Respondent: Yare Valley Society
The Yare Valley Society strongly supports the commitment in Policy 3 to protect and enhance the Green Infrastructure Network illustrated in map 8 of which the Yare Valley Corridor is an important part.
However, if Policy 3 is to be enforced and have any meaning, Site GNLP0133-E, which intrudes deeply into the existing Yare Valley Green Infrastructure Corridor should be removed from the draft GNLP Sites Plan list. Not to do so would display a blatant willingness to ignore Policy 3 from the outset.
The Yare Valley Society strongly supports the commitment in Policy 3 to protect and enhance the Green Infrastructure Network illustrated in map 8 of which the Yare Valley Corridor is an important part.
However, if Policy 3 is to be enforced and have any meaning, Site GNLP0133-E, which intrudes deeply into the existing Yare Valley Green Infrastructure Corridor should be removed from the draft GNLP Sites Plan list. Not to do so would display a blatant willingness to ignore Policy 3 from the outset.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21264
Received: 16/03/2020
Respondent: Anglian Water Services Ltd
Anglian Water is generally supportive of the principle of development proposals providing biodiversity net gain. The policy as drafted says this would apply to development wherever feasible. However the Environment Bill which is currently before parliament refers to biodiversity net gain being mandatory for all development requiring planning permission.
Policy 3 should be amended for consistency with the provisions of Environment Bill.
Anglian Water is generally supportive of the principle of development proposals providing biodiversity net gain. The policy as drafted says this would apply to development wherever feasible. However the Environment Bill which is currently before parliament refers to biodiversity net gain being mandatory for all development requiring planning permission.
Policy 3 should be amended for consistency with the provisions of Environment Bill.
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21304
Received: 16/03/2020
Respondent: Lanpro Services
Agent: Stephen Flynn
Lanpro contend that the GNGB’s approach to the natural environment as set out in Policy 3 of the Regulation 18, Stage C Consultation Document, specifically the lack of any discernible or deliverable site for a new country park, is ‘unsound’.
Lanpro request that before any further strategic scale growth can be planned through the Greater Norwich Local Plan, that South Norfolk Council establish a proposal for a realistic and deliverable new network of SANG’s.
The National Planning Policy Framework (the NPPF) places great weight on protecting and enhancing the natural environment. It seeks to ensure that development not only avoids harm to natural environmental assets but also encourages Local Plans to actively protect, promote and enhance biodiversity so that development results in net gain (paragraph 174).
An Interim Habitats Regulations Assessment (HRA) has been published alongside the Local Plan Regulation 18, Stage C Consultation Document. This deals specifically with the potential impact of the draft Local Plan Growth Strategy on designated ecological habitats, including the Broads and the Norfolk Coast in accordance with the NPPF.
The HRA identifies a range of mitigation measures that may assist in alleviating recreational pressure from new housing sites identified in the Regulation 18, Stage C Consultation Document. These include (i) the provision of new, alternative green space (referred to in the HRA as SANGS) and (ii) a programme of improvements to existing areas of infrastructure. The HRA confirms that the SANG could take the form of a new country park containing woodland and waterbodies.
This need for additional, useable and attractive green infrastructure within Greater Norwich in order to mitigate proposed growth is not a new one. The Greater Norwich Development Partnership (GNDP) undertook an Open Spaces Indoor Sports and Community Recreation Assessment (OSISCRA) using Planning Policy Guidance 17 (PPG17) assessment methodology in September 2007.
This OSISCRA concluded that there was a requirement in 2007 to deliver 87.5 sq. m of combined formal, seminatural, amenity, play, sports and outdoor spaces per person resident in South Norfolk Council area. The OSISCRA went on to conclude that South Norfolk Council did not have a large enough network of public open spaces (at the start of the adopted Joint Core Strategy review) to meet the needs of the District.
Since 2007 this Habitat Regulations problem within South Norfolk has worsened due to large scale housing growth and the Council’s failure to implement a strategy to deliver new natural and semi-natural green spaces to manage this impact.
Whilst the current Joint Core Strategy identifies the potential to create a new country park at Bawburgh Lakes to mitigate the impact of its growth strategy, this site remains undelivered. The Joint Core Strategy for Norwich, Broadland and South Norfolk Annual Monitoring Report strategy 2016-2017 published April 2018 (AMR) has since confirmed that there has been no net increase in the amount of natural and semi-natural open spaces delivered within South Norfolk Council area since the 2007 assessment and thus the impact of the existing Local Plan growth strategy remains unmitigated.
Despite this and the requirement for new SANGs to mitigate the additional recreational pressure to be created by the emerging Local Plan, there is no site identified within the Regulation 18 Stage C Consultation Document for a new Country Park. To the contrary, footnote 74 of the Regulation 18, Stage C Consultation Document defers consideration of potential sites for a new Country Park to the Regulation 19 stage.
In the absence of any identified deliverable sites for a Country Park within the Regulation 18, Stage C Consultation Document, draft Policy 3 requests that new development provide onsite infrastructure as necessary. In addition, and rather than allocating sites, the plan suggests that new country parks can be identified through green infrastructure strategies and be funded in the most part, by CIL.
Lanpro contend that the GNGB’s approach to the natural environment as set out in Policy 3 of the Regulation 18, Stage C Consultation Document, specifically the lack of any discernible or deliverable site for a new country park, is ‘unsound’.
Lanpro request that before any further strategic scale growth can be planned through the Greater Norwich Local Plan, that South Norfolk Council establish a proposal for a realistic and deliverable new network of SANG’s. This could be achieved in part, through the allocation and early release of a Country Park at Caistor Lane (GNLP 0485).
The proposed Country Park at Caistor can be delivered at a scale and in a form that ensures its attractiveness to new visitors, thus diverting visitors away from The Broads National Park and existing Natura 2000 sites, SAC’s and SSSI’s present within the District.
Importantly, the set-up and long-term maintenance of this new park will be funded by housing delivery across the same site and would not be reliant on the public purse.
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21476
Received: 12/03/2020
Respondent: Hempnall Parish Council
Paragraphs 183 and 184 talk about the great weight placed on protecting the natural environment in Greater Norwich, but then there are no clear details on how this will be achieved. Provision of a Green Belt would go some way to addressing this.
Please see attached for consultation response from Hempnall Parish Council.
Please see also the Hempnall Parish Council Position Statement on sites in Hempnall proposed by landowners for inclusion in the GNLP - included with this submission. This Position Statement, which deals directly with the detail of what Hempnall Parish Council wants for Hempnall, should be considered alongside our consultation response which makes a number of more general comments about the Draft GNLP.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21543
Received: 16/03/2020
Respondent: Hingham Town Council
Sites should not be allocated for development when they are so clearly contrary to the policies that should be applied and would permanently destroy the natural environment and have a detrimental impact on landscape
With regard to the Natural Environment –“ Development proposals will be required to conserve and enhance the natural environment. Key elements of the natural environment include valued landscapes”. Again with specific reference to GNLP0520. Development of GNLP0520 would be contrary to Policy 3 “The Natural Environment …. Development proposals will be required to conserve and enhance the natural environment. Key elements of the natural environment include valued landscapes” … it is clear from residents objections that the loss of such prominent and valued open landscape by developing GNLP0520 would definitely not “conserve or enhance the natural environment”, but permanently destroy it, on the approach to Hingham via the Norwich Road.
Sites should not be allocated for development when they are so clearly contrary to the policies that should be applied.
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21680
Received: 16/03/2020
Respondent: The Woodland Trust
Need for more specific policy on protection ancient woodland and ancient/veteran trees, at least as strong as that in the NPPF. Also there is a need for specific policy and/or targets on tree planting and woodland creation.
We have to object to Policy 3 as written. Whilst it contains some good policy and is obviously well intentioned, we believe that some of the wording is not sufficiently strong on habitat protection and in particular in protection offered to irreplaceable habitats, such as ancient woodland and ancient/veteran trees. We would like to see protection given to these habitats which is at least as strong as the protection given in Para 175c of the NPPF, where it states that any development having adverse impacts on ancient woodland and/or veteran trees will be wholly exceptional.
We have made a separate submission on your site allocations, as we believe that allocation GNLP0132 will adversely impact an area of ancient woodland. We have submitted a letter with our objection, which goes into much more detail on this point. It is possible that lack of strength in the wording of policy 3 is one of the factors which allows such site allocations to be put forward.
We would also like to echo the words of the local parish council which has commented on Policy 3 to the effect that their is a lack of specific reference to woodland creation or tree planting and that this is a significant omission, given current concern over the climate emergency. The Woodland Trust has recently published an Emergency Tree Plan in which we are urging that both protection of existing trees and ambitious targets for planting new trees and woods must have an important role in any local climate action plan. In its recent election manifesto, the current Government made a commitment to creating 30,000 hectares of new woodland each year, which is equivalent to 30 million trees per year and the importance of tree planting was also stressed in DEFRA's 25 Year Environment Plan.
There are some references in the supporting text to creation of some new country parks and these may well include some trees and woods but there is no explicit requirement for this in the policy.
The precise form of any planting target is a matter for debate but in the Emergency Tree Plan we have suggested that areas of new development should include 30% tree canopy cover. Your local plan could include an aim of measuring canopy cover (through one of the recognised techniques such as ITree) and an ambitious target for enhancing it, both on council owned land and on private land.
An alternative strategy adopted by some councils is set an ambitious target in terms of number of trees to be planted (eg one for every person in the area covered by the plan over 5 years, which would be in line with the target recently announced by Norfolk County Council.
Alternatively, you could use the Woodland Trust's Access to Woodland Standard, which aspires that everyone should have a wood of at least 2ha in size within 500 metres of their home and a larger wood of at least 20ha within 4km. Our report Space for People, available on our website, shows the percentage woodland access achieved by each council. For Norwich City it is 16.9% for the first part of the standard and 78.4% for the second part. We are happy to supply this information for the other councils in the joint planning unit, if that would be of assistance, and in your local plan you might want to set targets for % woodland access to be enhanced.
Support
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21744
Received: 16/03/2020
Respondent: Brown & Co
We support the approach to the natural environment.
The proposed new settlement Honingham Thorpe is well related to the existing green infrastructure network to the west of Norwich and it is proposed to link with this and enhance it. A comprehensive multi-functional green infrastructure network would be delivered within the site and form the spine of the development.
We support the approach to the natural environment.
The proposed new settlement Honingham Thorpe is well related to the existing green infrastructure network to the west of Norwich and it is proposed to link with this and enhance it. A comprehensive multi-functional green infrastructure network would be delivered within the site and form the spine of the development.
A key element of the proposed new settlement would be the delivery of a new country park to the south, along the Yare River Valley. Whilst the natural features are already present public access to these is poor. The proposals would help to alleviate visitor pressure on Natura 2000 sites elsewhere in the region, as well as providing the opportunity for educational facilities.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21766
Received: 16/03/2020
Respondent: RSPB (East of England Regional Office)
More detail is needed to demonstrate net gain and to ensure a robust in-combination assessment is undertaken in the HRA.
It is hard to comment on this due to the lack of detail and lack of detail describing which species and habitats are being considered. Mention is made of areas, locations and species being considered in promoting net gain, but these areas and locations are not described in any way making it hard to comment? Have swift nest boxes been considered as an essential design feature for new houses? RSPB is happy to advise if this would help.
Paragraph 188 mentions the HRA, but our opinion is this document isn’t thorough enough and considers potential sources of impact in isolation but not in combination. RSPB has evidence of such ‘in-combination’ impact from our nature reserves, specifically related to bird disturbance and the water environment.
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21834
Received: 16/03/2020
Respondent: Natural England
Natural England objects to the current wording of Policy 3 and considers that the policy and supporting text are inadequate to protect, maintain, restore and enhance the natural environmental assets of the area and the benefits arising from these for residents, workers and visitors. It will not ensure the delivery of GI of sufficient quality and quantity in the right locations, nor help the Plan to meet the sustainability criteria or adapt to climate change. It contains too much uncertainty and needs to explain the hierarchies of site protection and mitigation.
The natural environmental assets found in the Greater Norwich area, and adjoining it, provide immense benefits that deliver across all three pillars of sustainability. In terms of benefits to the economy and society alone, these would run into tens of millions of pounds if they were calculated over the lifetime of the Plan.
We strongly recommend that Policy 3 and the supporting text are substantially amended and expanded. The 175 words assigned to the current natural environment section of Policy 3 cannot do justice to what is required for the Greater Norwich area and surroundings. Much of the wording and maps in Policy 1: Addressing climate change and protecting environmental assets in the current Joint Core Strategy (2011) remains valid and relevant. Parts of it could form the basis of a new Policy 3, which needs to cover measures in relation to climate change adaptation, halting and reversing the loss of biodiversity in relation to the Government’s 25 year Environment Plan and Nature Recovery Networks, biodiversity net gain, recreational disturbance, suitable alternative greenspace (SANGS) and GI networks.
We also suggest looking at East Suffolk Council’s Local Plan Final Draft and Policy SCLP 10.1: Biodiversity and Geodiversity and the supporting text in general, for the approach that we endorse (https://www.eastsuffolk.gov.uk/assets/Planning/Suffolk-Coastal-Local-Plan/Final-Draft-Local-Plan/Final-Draft-Local-Plan.pdf).
GI references in the Plan repeatedly refer to the strategic GI network as set out on the (basic) Map 8 and very little else. The Local Plan needs to provide a strategic document that sets out what the GI network will look like on the ground, how and where it will be delivered and the timescale, together with detailed information about the existing GI network and how it, too, will be protected, enhanced or expand. At this stage of the plan process there needs to be far more detail provided to be certain that it will be delivered, and for the HRA to be able to assess in relation to the mitigation measures that have been identified.
Natural England, together with other partners, would very much like to work with the local authorities in revising and expanding Policy 3 to ensure it is comprehensive and robust.
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.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21851
Received: 12/03/2020
Respondent: Hempnall Parish Council
Paragraphs 183 and 184 talk about the great weight placed on protecting the natural environment in Greater Norwich, but then there are no clear details on how this will be achieved. Provision of a Green Belt would go some way to addressing this.
Please see attached for full submission
Support
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21946
Received: 13/03/2020
Respondent: UEA Estates & Buildings
Agent: Bidwells
The UEA are supportive of the strategy to ensure that development proposals conserve and enhance the built, historic and natural environment.
As outlined within the Representations for GNLP0133-B, GNLP0133-C, GNLP0133-D, and GNLP0133-E, Historic England consulted on the potential designation of the landscape surrounding the UEA as Historic Parkland (Case: 1466188). Notwithstanding this, regardless of whether the landscape is designated as Historic Parkland, development on each site will be designed in a manner to respect the visual setting of the UEA, whilst facilitating the growth and expansion of the UEA.
Please see attached for full submission
Support
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21990
Received: 16/03/2020
Respondent: Ms Carol Sharp
We welcome the support of the NSPF objectives on environmental protection, landscape protection and biodiversity and the statement that development should deliver biodiversity net gain but it is short on specifics of how this will be measured.
We welcome the commissioning of the Norfolk-wide study, the Green infrastructure and Recreational Impact Avoidance and Mitigation Strategy see comments above.
Please see attached for full submission
Support
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 21997
Received: 13/03/2020
Respondent: Redenhall with Harleston Town Council
The Town Council supports Policy 3 (Environmental Protection and Enhancement) and the measures detailed to conserve and enhance the natural environment including valued landscapes, biodiversity including priority habitats.
please find attached the report which was agreed by resolution by Harleston Town Council on March 11th 2020.
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22022
Received: 15/03/2020
Respondent: Mulbarton Parish Council
With the development of industrial areas in the A140, B113 and A47 triangle MPC are disappointed that there is no provision of a Green Belt on a ‘green wedges’ model to prevent continual urban sprawl from Norwich to the rural village of Mulbarton.
Please see attached for full submission
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22187
Received: 16/03/2020
Respondent: Environment Agency (Eastern Region)
This policy contains a statement which states “development should deliver biodiversity net gain wherever possible”. Once the Environment Act has become legislation, this statement must be strengthened.
The policy around the natural environment must be clarified as it seems muddled. There should be separate statements for accessible green space (which could be integrated with biodiversity enhancements) and natural habitats (whose conservation value may be compromised by full public access). Overall, the importance of the natural environment in its own right needs to be recognised.
Paragraph 197 states that the Environment Bill is currently being considered in parliament. However, government policy has now made net gain mandatory and this should therefore be updated within the plan.
In regards to paragraph 191 - The creation of Country Parks on areas already identified as priority habitat under the NERC (for example Bawburgh lakes and Horsford) could bring both negative and positive impacts on these habitats. Sensitive management could benefit some species, however the impacts of increased visitor pressure, disturbance from dogs and so on, will have to be carefully assessed to ensure that there is no deterioration in the quality of these habitats.
We would encourage the plan to incorporate new areas that are currently of limited value to wildlife (agricultural land) and create new habitats and parks in these locations. These areas could be strategically planned to increase the connectivity of existing habitats. On suitable agricultural land, the creation of new parks would bring immediate unquestionable net gain and could improve habitat connectivity as well as improving the green infrastructure network.
It is disappointing that the does not include any reference to environmental legislation. There needs to be reference in this section to WFD (outlining key objectives, no deterioration & improvement in waterbody status) and habitats directive which is particularly important to this district. For the policy itself, we suggest adding the following text: "...Key elements of the natural environment include valued landscapes, biodiversity including priority habitats, networks and species, geodiversity, a high quality and plentiful water environment, high quality agricultural land and soils."
The policy should also include a paragraph around encouraging redevelopment of brownfield sites, with appropriate risk assessment to protect the water environment. This policy discusses "enhances" but again does not reference WFD which is a key piece of legislation supporting and setting specific targets for enhancement. This needs amending.
Please see attached for full submission
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22258
Received: 16/03/2020
Respondent: Carter Jonas LLP
Number of people: 2
Land at Green Lane West, Rackheath
It should be noted that national guidance expects planning decisions to contribute towards and enhance the natural environment, and to secure measurable net gains for biodiversity – see Paragraphs 170 and 174 of the NPPF. It should be acknowledged that development can deliver ecological enhancements and net biodiversity gains. The proposed allocation at Green Lane West in Rackheath would include ecological enhancements. The case officer for the planning application accepted that the site currently has limited ecological value and the open space is not managed, and concluded that the proposed development would lead to a net gain in biodiversity.
Land off Townhouse Road, Costessey
The promoted development at Townhouse Road in Costessey would include ecological enhancements. Where possible, hedgerows at the boundaries of the site should be retained and enhanced to create corridors and shelter/foraging areas for wildlife including birds, bats, badgers and hedgehogs. Planting of native hedgerow species in gaps, for example along the southern and eastern boundaries will provide further opportunities for these species and enhance their value as ecological corridors.
The addition of bat boxes to any new buildings or retained trees within the site would provide additional roosting opportunities. Schwegler bat boxes are recognised as being suitable for roosting bats and long lasting. Bat boxes should ideally be located south facing (between south-east and south-west) and above 5m. Boxes such as Schwegler 2F or integral bat tubes Schwegler 1FR suitable for pipistrelles would be suitable for this site.
Landscaping could incorporate native or wildlife attracting trees, shrubs, and wildflower areas as these would likely be of benefit to a variety of wildlife including, birds, bats and invertebrates. Such landscaping could also act as a receptor area should reptiles be recorded using the site and require translocation.
The incorporation of a reptile hibernaculum into the landscape design (preferably within any wildflower grassland) will enhance the area for reptiles in the future. Hibernacula can be created by partially burying piles of wood/rubble and covering with earth. Hibernacula in the form of log piles could also benefit hedgehogs.
The addition of a range of bird boxes would provide additional nesting opportunities. This could include house sparrow terraces on any new buildings on site providing additional nesting opportunities for this BoCC red listed species recorded on/over site. Further standard bird boxes sited on mature trees will help attract a greater diversity of birds to nest. Boxes should be located out of direct sunlight and close to, but not restricted by, vegetation. A suitably qualified ecologist should be consulted to determine the exact location and position of the bird boxes.
The addition of insect houses/hibernacula within retained or created wildflower grassland would retain shelter and hibernation opportunities for invertebrates using the grassland or boundary habitats.
On behalf of my client, Taylor Wimpey Strategic Land, please find attached representations relating to Land South of Townhouse Road, Costessey, and Green Lane West, Rackheath.
Object
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22412
Received: 16/03/2020
Respondent: Norwich Green Party
We lack confidence in GNLP's desire to protect the natural environment in light of:
- Development of significant green open spaces in Greater Norwich eg Royal Norwich Golf Club for housing, Yare valley on Bluebell Road for housing, Yare valley land off Colney Lane for new Rugy club and parking, redevelopment of Blackdale school and playfields for student housing.
- NDR which has severed a large area of open countryside. Post-evaluation of landscaping showed that a high percentage of trees and shrubs planted along the road have died.
- GNLP policy support for extension of NDR across River Wensum Valley with its complex mosaic wetland and woodland of habitats.
- GNDP Councils' support for A47 dualling, eg North Tuddenham to Easton dualling would adversely impact upon the Tud valley.
Natural green spaces are seen as an easy target for development and the city is expanding further and further outwards into open countryside. The GNLP must take seriously the Biodiversity Emergency and the need to achieve 'Net Biodiversity Gain' at every opportunity.
For full representation and additional information submitted, please refer to the attached documents.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22458
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 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 Long Lane,
Costessey is shown to be included within the Green Infrastructure Corridor which aligns with the
western edge of Norwich. Despite this designation, there have been planning applications
approved within the identified Green Infrastructure Corridors, including the land to the north of the
Site at Lodge Farm.
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. Gladman considers that the focus of Policy 3 in relation to Green Infrastructure should be
to secure environmental benefits at the planning application stage to enhance the quality and extent of the corridors with 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.
2.2.3 Should wording on protection of Green Infrastructure corridors be retained in the policy, Gladman
considers that further evidence is needed to set out what elements of the Green Infrastructure
corridors need to be protected and for what reason. It should also be set to a greater level of detail
what is meant by the term “effective management of development in accordance with the policies
of the development plan”. 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 in Green
Infrastructure.
Please find attached the representations of Gladman made specifically in relation to our land interest in Costessey
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
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.
Please find attached the representations of Gladman made specifically in relation to our land interest in Wymondham