Policy 3 Environmental Protection and Enhancement

o The Built and Historic Environment – first bullet point – it states developers should be ‘undertaking a heritage impact assessment if significant impacts might arise’ – government guidance states that this is required for any application that affects any heritage asset or their setting – including locally identified heritage assets. Is the wording therefore needed and if so does it need re-wording?
o Policy 3 second bullet point – ‘public benefits’ might be better wording than ‘benefits’. Should this be re-worded to put the emphasis on avoiding harm to Heritage assets?
o Policy 3 - The Built and Historic Environment – last sentence states ‘importance of the heritage asset’, for the sake of consistency of terminology would ‘significance of the heritage asset’, as per the NPPF, be better?
o Policy 3 – Natural Environment – first para – it states ‘ancient trees and woodland’ should be protected. Could this be broadened out to include other trees which contribute greatly to our settlements and green spaces?

We have a number of comments and observations. We do not think they are soundness issues, but the changes are needed, in our opinion, to make the plan better, clearer and more consistent. We believe they can be addressed as additional modifications.

Comments on Strategy document
Main points
The following points are quite important, but are not soundness issues. They do not affect the soundness of the Local Plan. They can however be easily added to the Local Plan to provide context, especially given the stance in the Plan that the sites in East Norwich are seen as one, including the part in the Broads. Other comments would aid clarity. These comments could be addressed as additional modifications.
• Policy 3
o The Built and Historic Environment – first bullet point – it states developers should be ‘undertaking a heritage impact assessment if significant impacts might arise’ – government guidance states that this is required for any application that affects any heritage asset or their setting – including locally identified heritage assets. Is the wording therefore needed and if so does it need re-wording?
o Policy 3 second bullet point – ‘public benefits’ might be better wording than ‘benefits’. Should this be re-worded to put the emphasis on avoiding harm to Heritage assets?
o Policy 3 - The Built and Historic Environment – last sentence states ‘importance of the heritage asset’, for the sake of consistency of terminology would ‘significance of the heritage asset’, as per the NPPF, be better?
o Policy 3 – Natural Environment – first para – it states ‘ancient trees and woodland’ should be protected. Could this be broadened out to include other trees which contribute greatly to our settlements and green spaces?
• The map on page 100 needs to show the part of the utilities site in the Broads. The preceding text talks about looking at the area as a whole, yet misses the bit of the Utilities Site that is in the Broads.
• Policy 7.1, page 105, there needs to be some acknowledgement in this policy, even if it is a footnote, to say that part of the Utilities site is in the Broads and that the entire area is being considered together, regardless of local planning authority administration boundaries.
• Para 205 – ‘The strategic approach to heritage is first to consider the potential location of development, for example does the location itself “fit” well in relation to adjoining settlements’. We are not entirely clear what this means. Does it mean that new development should relate well to its historic context?
• Para 205 - goes on to state that development should avoid intruding into important views of historic assets. Historic England guidance on the Setting of Historic assets (The Setting of Heritage Assets (historicengland.org.uk)) and numerous appeal decisions make clear that the setting of a heritage asset is much greater than views and it is the setting of heritage assets that need to be considered not specific views.
• Para 205 - Also ‘historic assets’ is used – should the term be heritage assets to ensure it correlates with the terminology defined in the NPPF?
• Para 207 – should this state ‘public benefits’ not just benefits?
• Para 207 – This paragraph recognises that in certain circumstances a balance will need to be struck between development and protection and this recognition is useful. It might be helpful if this section was weighted more towards protection of the historic environment, taking a precautionary approach. The NPPF states that substantial harm to grade II listed HAs should be exceptional and to SAMs or grade II* / grade I HAS should be wholly exceptional (para 194). Equally para 195 of the NPPF states applications should be refused where a proposal will lead to substantial harm unless there are substantial public benefits that outweigh that loss or all of 4 tests can be met.
The reason for the following is not explained and is different to the NPPF. Depending on what is meant, it could affect the setting of the Broads. We would welcome some explanation around the wording used and also its justification.
• Policy 7.4, page 117 seems to imply that rural exception sites or entry level exception sites can be ‘well related’ to settlement boundaries. The NPPF says that such sites should be adjacent. Why is this approach being changed? It does not seem to be explained anywhere in the document. What is well related as well? How far from a settlement boundary can a development be? Depending on what is meant, this could affect the setting of the Broads and we may strengthen the status of our comment later in the examination process. Perhaps of relevance are the changes to the NPPF that are proposed to the current paragraph 172, proposed paragraph 175: ‘The scale and extent of development within these designated areas should be limited, while any development within their settings should be sensitively located and designed to avoid adverse impacts on the designated landscapes’.
The following points are not soundness issues, but the plan could easily be amended to include them. It seems logical to address these comments as additional modifications. They provide clarity and context and further useful information.
• Policy 2, bullet 5 – would welcome, perhaps in a footnote, reference to the landscape character assessment for the Broads, so it is clear that our LCA might be of relevance as well.
• Policy 7.1, page 106, last bullet point – you might want to have a footnote that refers to the local plan for the Broads and our policies on navigation.
Minor comments
Minor points for you to consider. These could aid clarity. They could be additional modifications.
• 10.3 – should this also refer to off shore wind’s on-shore infrastructure?
Typo and grammatical errors
Typos and grammatical errors for you to consider
• Page 105: Development of sites allocated in the East Norwich strategic regeneration area identified on the Key Diagram and defined on map 9 including Carrow Works, the Deal Ground and the Utilities Site will create a highly sustainable mixed-use gateway quarter accommodating substantial housing growth and optimising economic benefits. Development across the sites will provide in the region of 4,000 additional homes in the plan period and significant new employment opportunities for around 6,000 jobs. East Norwich also has the potential to act as a long-term catalyst for regeneration of the wider area, potentially including the following sites if they become available:
• Page 106: • creating an inclusive, resilient and safe community in which people of all ages have good access to high quality homes that meet housing needs, the provision of area-wide economic and social infrastructure and services, including (but not limited to) the creation of new employment opportunities, a new local centre, and a new primary school should need to be established’.
Comments on the sites document
The following points are quite important, but are not soundness issues. They do not affect the soundness of the Local Plan. They can however be easily added to the Local Plan to provide context. Other comments would aid clarity. These comments could be addressed as additional modifications.
• Throughout the various parts - as this is a planning document, no need to say ‘National Park’. Just say ‘the Broads’. There are many occurrences, so perhaps search for the term.
• It would be useful if all of the site allocation plans had street names on – the required standard for most planning applications is at least two street names.
• We note there is no mention of dark skies or limiting light pollution in the policies. The Broads has intrinsically dark skies, as can be seen at this map. We therefore recommend that wording could be added.
Norwich sites
The following comments are factual, observations, seek clarity, seek consistency or are typographical or grammatical. They are not soundness issues, but the comments could be addressed as additional modifications.

Observation:
As a matter of consistency. We note that para 2.198 says this ‘Given the site’s highly accessible location and the intention to provide new public transport links it is considered suitable to include car-free housing. In any event car parking levels should be kept low’. We note that other sites may say that the site is considered suitable for car free housing, but the wording in those instances does not go on to talk about the last part – car parking levels should be kept low. You may want to check to see if this wording is needed for other allocations.

0360/3053/R10
Main points
• Map page 15, this needs to show the part of the utilities site that is in the Broads. This does not affect the soundness of the Local Plan. It could, however, be easily added to the Local Plan to provide context, especially given the stance in the Plan that the sites in East Norwich are seen as one, including the part in the Broads.
• We request that wording like that at 2.134 is included in the supporting text for CC4b. ‘2.134 The site lies adjacent to the River Wensum. It is recommended that developers engage in early discussions with the Environment Agency and the Broads Authority’. Considering what is written at 2.134 and considering the similarities in the location of the site, it seems logical to be consistent and include the Broads Authority as suggested.
Minor points
• Page 12, point 6 of policy. Typographical/grammatical error: ‘heritage assets affected by the proposal on and off site including key views from and into the site’.
• Page 12, point 8 of policy – something to consider. You may wish consider biodiversity on this brownfield land that may establish or has been established over the years. Open mosaic habitat of intrinsic biodiversity value is a NERC Act habitat. Brownfield sites are listed as a Priority Habitat in Section 41 of the Natural Environment and Rural Communities Act 2006 (NERC Act), as ‘open mosaic habitat on previously developed land’. For more information go here www.buglife.org.uk/sites/default/files/Identifying%20open%20mosaic%20habitat.pdf and here jncc.defra.gov.uk/pdf/UKBAP_BAPHabitats-40-OMH-2010.pdf
0068
Main points
• As part of point 1, refer to the scheme making the most of its riverside location, as is stated in other policies. This is a matter of consistency. 0401 and GNLP0409AR for example have good wording in point 1 that can be used. It is not clear why this wording is in most, if not all other river side policies and not this one. This may simply be a drafting error. This would make the plan consistent.
• 2.30 – support the fact that early engagement with us is recommended, but not clear why the only reason is flood risk. Or does that part of the sentence only refer to AWS? It may need clarifying that in general, given its location, early engagement with the Broads Authority is recommended, rather than just saying to do with flood risk.
Minor points
• Typographical/grammatical error: ‘Missing full stop:(or if developed for student accommodation, a minimum of 125 student bedrooms). A small element of commercial, office, and/or educational use at ground floor level may also be acceptable’.
0401
Main point
• We request that wording like that at 2.134 is included in the supporting text for CC4b. ‘2.134 The site lies adjacent to the River Wensum. It is recommended that developers engage in early discussions with the Environment Agency and the Broads Authority’. Considering what is written at 2.134 and considering the similarities in the location of the site, it seems logical to be consistent and include the Broads Authority as suggested.
Minor point
• Typographical/grammatical error: 2.51: ‘The site is likely to accommodate at least 100 homes, or if the site is developed to include student accommodation (at least 250 bedrooms)’. Suggest removing brackets as the sentence is not really reading well or right as drafted.
Cc4b
Main point
• We request that wording like that at 2.134 is included in the supporting text for CC4b. ‘2.134 The site lies adjacent to the River Wensum. It is recommended that developers engage in early discussions with the Environment Agency and the Broads Authority’. Considering what is written at 2.134 and considering the similarities in the location of the site, it seems logical to be consistent and include the Broads Authority as suggested.
Minor point
• Typographical/grammatical error: 2.121: ‘Development of site CC4a should explore continued use/re-provision of the existing community garden facility’.
Cc7
Main point:
• 2.131: the trees seem to be in the Conservation Area and so have some protection. You might want to refer to that.

CC16
Main point
• 2.203 – we request that this is worded like 2.134 as follows: ‘2.134 The site lies adjacent to the River Wensum. It is recommended that developers engage in early discussions with the Environment Agency and the Broads Authority’. At the moment, what is worded only refers to the EA. Considering what is written at 2.134 and considering the similarities in the location of the site, it seems logical to be consistent and include the Broads Authority as suggested.
Minor point
• Does not mention about making most of riverside location in supporting text like other policies. The actual policy does. You may wish to add something to the supporting text to be consistent.
Urban fringe
The following comment is factual. It is not a soundness issue, but it seems logical to address these comments as additional modifications.
Factual update
• Para 3.75 – last sentence, amend as follows ‘the Church of St Andrew and its ruins’ – as both the church and ruins are listed.
Key service centres
The following comment seeks to improve context. It is not a soundness issue, but it seems logical to address these comments as additional modifications.
Main point:
• GNLP0378R/GNLP2139R, GNLP0312 and para 5.42 – please also mention dark skies of the Broads. The Broads has intrinsically dark skies. You mention the setting of the Broads, which is welcomed, but please add reference to protecting the dark skies of the Broads.
Broadland villages
The following comments are factual, observations, seek clarity, seek consistency. They are not soundness issues, but it seems logical to address these comments as additional modifications.
Main points:
• Cantley map, page 15 – show the Broads for consistency and to show the context.
• Horstead and Coltishall map, page 25 – show the Broads for consistency and to show the context.
• GNLP1001 – please also mention dark skies of the Broads. The Broads has intrinsically dark skies. You mention the setting of the Broads, which is welcomed, but please add reference to protecting the dark skies of the Broads.
• Coltishall, Horstead and Belaugh – should the Conservation Areas that covers parts of all three of these villages be mentioned in the text?
• Salhouse – again should the Conservation Area be mentioned – potential for limited impact on the wider setting of the CA at the site allocated in Salhouse.

General: we are unable to tell from the Green Infrastructure Corridors maps if these include all the Norfolk B-Lines, including the Chet Valley B-Line. The National B-Line launch takes place 23/03/2021, but the routes in Norfolk are already well known.
GNLP “Tools such as the Defra biodiversity metric should be used to demonstrate the expected biodiversity net gain that will be achieved through development.”
GNLP “It will need to be demonstrated that the gain to biodiversity is a significant enhancement (at least a 10% gain) on the existing situation.”
Concern: SMART targets need to be applied to BNG. They should be Specific, Measurable. Attainable, Relevant and Time Specific.
Concern: unless all LAs use the same tool no consistent measurement will be possible. Similarly, LAs should follow the same assessment and monitoring procedures, practices, and principles to ensure consistency. We recommend the CIRIA Good Practice Principles for Development: a practical guide. We also understand that a new British Standard BS8683 is being developed.
Concern: all LAs need access to specialist ecological advice and to be able to identify sites of ecological value that may have no formal designation e.g., brownfield. Within the B-Line corridors we recommend surveys are conducted using Buglife’s Good Planning Practice for Invertebrates: Surveys.
Concern: Developers should be penalised if they reduce the sites biodiversity value before submitting applications. Habitat removal prior to application submission can seriously reduce biodiversity value and should be strictly discouraged by measuring value prior to removal.
Concern: The BNG 10% gain should be time specific and prior to the developer relinquishing responsibility for the site.

General: we are unable to tell from the Green Infrastructure Corridors maps if these include all the Norfolk B-Lines, including the Chet Valley B-Line. The National B-Line launch takes place 23/03/2021, but the routes in Norfolk are already well known.
GNLP “Tools such as the Defra biodiversity metric should be used to demonstrate the expected biodiversity net gain that will be achieved through development.”
GNLP “It will need to be demonstrated that the gain to biodiversity is a significant enhancement (at least a 10% gain) on the existing situation.”
Concern: SMART targets need to be applied to BNG. They should be Specific, Measurable. Attainable, Relevant and Time Specific.
Concern: unless all LAs use the same tool no consistent measurement will be possible. Similarly, LAs should follow the same assessment and monitoring procedures, practices, and principles to ensure consistency. We recommend the CIRIA Good Practice Principles for Development: a practical guide. We also understand that a new British Standard BS8683 is being developed.
Concern: all LAs need access to specialist ecological advice and to be able to identify sites of ecological value that may have no formal designation e.g., brownfield. Within the B-Line corridors we recommend surveys are conducted using Buglife’s Good Planning Practice for Invertebrates: Surveys.
Concern: Developers should be penalised if they reduce the sites biodiversity value before submitting applications. Habitat removal prior to application submission can seriously reduce biodiversity value and should be strictly discouraged by measuring value prior to removal.
Concern: The BNG 10% gain should be time specific and prior to the developer relinquishing responsibility for the site.

Policy 3: Environmental Protection and Enhancement

Policy 3 seeks to protect and enhance the historic and natural environment including landscapes. The promoted development by Mrs Janet Skidmore at land south of Gonville Hall Farm in Wymondham (Site Ref. GNLP0320) would protect heritage assets and enhance the landscape as demonstrated in the Concept Masterplan for the development. The promoted development includes areas of parkland at the northern part of the site to protect the setting of Gonville Hall and views of Wymondham Abbey. The promoted development would include substantial areas for green corridors, green infrastructure and open space in order to provide opportunities for recreation, wildlife habitats and biodiversity enhancements. The promoted development could meet the requirements of Policy 3.
No modifications are required to Policy 3.

No specific modifications are required to Policy 3. However, it is requested that the site assessment is corrected, and modifications are made to the proposed allocation in Marsham, including that Site Allocation GNLP2143: Land south of Le Neve Road is deleted, so that the requirements of Policy 3 can be achieved.

Policy 3: Environmental Protection and Enhancement

Policy 3 seeks to protect and enhance the historic and natural environment including landscapes. However, it is considered that the requirements of Policy 3 would not be met because of the proposed allocation at GNLP2143: Land south of Le Neve Road in Marsham, on the basis that development in this location would have a significant impact on heritage assets and landscape character. The heritage report and landscape appraisal submitted with the Noble Foods Ltd representation to Site Allocation GNLP2143 demonstrate that development at this site would adversely impact the setting and landmark qualities of the church tower at All Saints Church, and it would have an unacceptable impact on the character and appearance of the open land that currently forms part of the setting of the village and the church. As set out in the representations to Site Allocation GNLP2143, the findings of the landscape and heritage assessment for this site are not correct and the impacts would be more harmful and significant than predicted. Therefore, it is considered that the decision to allocate land south of Le Neve Road in Marsham for residential development would not comply with the requirements in Policy 3 for development to protect and enhance the historic and natural environment.

As a resident of Norwich I would like to express my views on and criticism of the Greater Norwich Local Plan.

The Plan is unsound because the Norwich Western Link Road should not be included in the Plan. This proposed road scheme is not compatible with planned carbon reduction objectives. The proposed road should also not be in the Plan because there are many insurmountable planning issues associated with it, in relation to Wensum SAC and the concomitant Habitats Regulations. The Wensum is a precious chalk stream habitat.

The Plan is unsound because it lays out no coherent policy on climate change, and proposes no carbon budget for the area.

The Plan is unsound because it massively increases housing numbers beyond what the government is requiring, numbers in excess of what is environmentally sustainable.

The Plan is unsound because it does not amount to "balanced sustainable development" and does not comply with UN Sustainable Development goals to protect the environment whilst achieving social and economic gains.

As a resident of Norwich I would like to express my views on and criticism of the Greater Norwich Local Plan.

The Plan is unsound because the Norwich Western Link Road should not be included in the Plan. This proposed road scheme is not compatible with planned carbon reduction objectives. The proposed road should also not be in the Plan because there are many insurmountable planning issues associated with it, in relation to Wensum SAC and the concomitant Habitats Regulations. The Wensum is a precious chalk stream habitat.

The Plan is unsound because it lays out no coherent policy on climate change, and proposes no carbon budget for the area.

The Plan is unsound because it massively increases housing numbers beyond what the government is requiring, numbers in excess of what is environmentally sustainable.

The Plan is unsound because it does not amount to "balanced sustainable development" and does not comply with UN Sustainable Development goals to protect the environment whilst achieving social and economic gains.

Policy 3 seeks to protect and enhance the historic and natural environment including landscapes.
The proposed allocation at land to the west of Green Lane West in Rackheath (Ref. Policy GNLP0172) does not contain any listed buildings and is not within a conservation area. The proposed area of open space is located within Rackheath Park, which is the grounds associated with Rackheath Hall (Grade II Listed Building), but no buildings would be located within this area. The site has high archaeological potential associated with the medieval period, but the geophysical survey undertaken for the planning application identified no archaeological features, and for the planning application it has been recommended that a condition is attached to the planning permission requiring a programme of archaeological mitigation work.
There are no statutory or non-statutory landscape designations that affect the site, and there is no evidence to indicate that the site is valued for its landscape qualities. A full Landscape and Visual Impact Assessment (LVIA) has been prepared for the proposed development site and was submitted with the planning application. To the north of the site is a residential area at Trinity Close and Sir Edward Stacey Road. To the south is commercial uses. The proposed strategic development at the North Rackheath Urban Extension is located to the east of the site. The site is enclosed by a dense hedgerow and hedgerow tree planting to the east, which forms a natural green boundary and screens the site in views from the east. The Norwich Northern Distributor Road is located to the west of the site. The majority of the existing vegetation within the site will be retained within the proposed development. The proposed residential areas will include landscaping and structural planting. The proposed development includes a substantial area to the east of the new NNDR for landscape enhancement and new wildlife habitats. It is concluded in the LVIA is that the site is a suitable location for residential development in terms of landscape and visual impacts, provided the landscape mitigation and enhancement measures are implemented. Therefore, it is considered that the proposed allocation would be consistent with the requirements of Policy 3.
No modifications are required to Policy 3.

Recommendation
20. The Council should:
• Delete the prefix “at least” to the 10% requirement for net gain; and
• Consider the impact on viability from the additional cost of delivering a 10% net gain in biodiversity.

For full submission view attachment.

Draft policy 3 of the GNLP does not refer specifically to County Wildlife Sites (‘CWS’) but states that development proposals will be required to conserve and enhance the natural environment avoiding harm to designated and non-designated assets of the natural environment unless there are overriding benefits from the development and the harm has been minimised. This means that a CWS designation does not preclude development, but it will be a high and undefined bar to demonstrate that the benefits of development overrides harm unless policy is clearer. We therefore propose that draft policy 3 is amended to set out a clear benefit a development can provide, such as a 10% biodiversity net gain. Draft Policy 3 is proposed to read as follows:

“Development proposals will be required to conserve and enhance the natural environment (including valued landscapes, biodiversity including priority habitats, networks and species, ancient trees and woodlands, geodiversity, high quality agricultural land and soils) through: • being designed to respect and retain, and add to, natural assets; taking account of local design and other guidance, and undertaking landscape, biodiversity or other appropriate assessments if significant impacts might arise; • avoiding harm to designated and non-designated assets of the natural environment unless there are overriding benefits from the development, for example at least a 10% biodiversity net gain, and the harm has been minimised”.

To be sound the Local Plan should be consistent with national policy, which means that policies should be clearly written and unambiguous (see paragraph 16(d), Framework). The amendments put forward at question 6 ensures draft policy 5 is clearly written and unambiguous.

Policy 3 should be redrafted to make it consistent with the terms of national policy and re-introduce the test of necessity required by paragraph 195 of the NPPF.


Bullet point 2 might simply read:

“avoiding harm to designated and non-designated heritage assets and historic character”.

If the Policy wishes to continue to highlight the potential benefit of new development within this historic built environment, then the text could add:

“ Developments which will cause harm to heritage assets and historic character will be refused unless it can be demonstrated that this is necessary in order to achieve other essential and substantial public benefits that could not be achieved by other means, and those benefits will outweigh the harm”.

In one specific respect, Policy 3 fails to be consistent with national policy (as expressed in the current National Planning Policy Framework) and the Plan is unsound to that degree.

The clear requirement of the NPPF is that developments which will cause substantial harm to a designated heritage asset should be refused, unless it can be demonstrated that this is “necessary to achieve other substantial public benefits that outweigh that harm” (paragraph 195). In effect, the potential harm has to be necessary, that is to say unavoidable, before the merits of any substantial public benefits can kick in and this policy test can be passed.

The current wording selected for Policy 3 turns this presumption on its head. Now, the claimed existence of “overriding benefits” can be used to trump the duty of “avoiding harm”. The ‘necessity’ rule in the NPPF is no more. A simple reading of the proposed policy suggests that the prospect of an “overriding benefit” could be used legitimately to justify a heritage harm or loss, whether that harm or loss was actually avoidable or not.

We would expect the policy to reference WFD as a starting point. It is important to reference water and water quality as this is something that designated sites rely on.

The policy should reference the Water Cycle Study and that development should be located in areas to avoid harm to the natural Environment.

Nothing has been added here in response to our comments referenced in our previous representation and as such they still stand. There is no mention of water quality at all and no acknowledgement of needing to protect it or risks from development. As previously stated, the policy does not reference WFD which is a key piece of legislation supporting and setting specific targets for enhancement and requires amending.

Anglian Water supports the requirement to provide 10% biodiversity net gain for developments in the Greater Norwich area having followed the mitigation hierarchy.

In policy 3 and / or its supporting text, further provisions that focus on CEPTED (Crime Prevention Through Environmental Design) based on the principles of the police initiative (SBD) Secure By Design would be welcome.

Norfolk Constabulary support multi-functional green infrastructure plans. The safe access and movement of people through green infra structure in particular is desired and where relevant Norfolk Police would request the adoption of CEPTED (Crime Prevention Through Environmental Design) based on the principles of the police initiative Secure By Design (SBD) to facilitate this. Crime prevention measures such as creating surveillance vistas to aid observations, extra lighting along designated routes/paths should benefit movement by reducing the opportunity for crime and the fear of crime to occur. Central Government place great emphasis on the role of the Police within planning consultations, furthermore National Planning Policy Framework (NPPF) gives significant weight to promoting safe communities (in section 8 of the NPPF).

Further provisions that focus on these issues would be welcome to ensure conformity with the NPPF and secure soundness to the Plan

Make the policy more locally specific.

Suggest reordering bullet points, 2, 1,
3.

Bullet point 1 We re-iterate our advice that HIAs are required to inform site allocations and as part of the evidence base for the Local Plan. These need to be completed before the EiP.

Amend bullet point 2 to more properly reflect the tests in the NPPF. You could add the phrase, ‘in accordance with the requirements of the NPPF’.

Amend bullet point 3 to also specifically refer to heritage at risk.

Include a separate paragraph in the policy after ‘importance of the heritage asset.’ To read, ‘The
Councils will maintain and update the Heritage at Risk Register and develop a strategy for addressing Heritage at Risk.’

Thank you for consulting Historic England on the Greater Norwich Local Plan Regulation 19 Draft including The Strategy and The Sites. As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the conservation and enjoyment of the historic environment.

Our comments below should be read with reference to our previous comments dated 1.2.17, 15.3.18, 4.12.1, 26.4.19 and 16.3.20. Please also see our detailed comments in the attached tables, Appendix A in relation to The Strategy and Appendix B regarding The Sites.

SUMMARY
The Greater Norwich Local Plan covers the Strategy and Site Allocations. While commenting on the plan as a whole, Historic England is particularly concerned, for its implications for Norwich itself. Norwich is one of England’s great historic cities, and its architectural and historic character, and the sense of place associated with that, make a profound and wholly beneficial contribution to the city’s well-being.

In line with paragraph 185 of the National Planning Policy Framework (NPPF) it is important that the Plan should set out a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats.

Please see the section addressing Policy 3 in the attached representations submitted on behalf of R Mason in support of the allocation of Land at Rightup Lane, Wymondham (Site GNLP0355)

Recommendation: It will be necessary to examine the implications of this requirement in an updated
Viability Assessment and if necessary revise the GNLP accordingly prior to submission.

Pigeon Investment Management Ltd (‘Pigeon’) welcome the opportunity to submit representations on the Greater Norwich Local Plan Pre-Submission Draft Strategy Regulation 19 Publication Stage (‘the GNLP’) on behalf of R Mason (‘the Landowner’) in support of the allocation of Land at Rightup Lane, Wymondham (GNLP0355).

Please find attached full representation and an Illustrative Site Layout Plan.

Please see the section addressing Policy 3 in the attached representations submitted on behalf of the Trustees of the WJ Gowing 1985 Settlement and the Trustees of the Howard Trust and Pigeon Capital Management 2 in support of the allocation of Land north of Brecklands Road, Brundall.

We are pleased to submit representations for Pigeon Investment Management Ltd and the landowners in support of Land north of Brecklands Road, Brundall (site GNLP0352). Please find attached response forms, the representations and a Delivery Statement.

Please see the section addressing Policy 3 in the attached representations submitted on behalf of Michael and Jackie Buxton and Pigeon Capital Management 2 Ltd in support of the allocation of Land at Dereham Road, Reepham.

We are pleased to submit representations for Pigeon Investment Management Ltd and the landowners in support of Land at Dereham Road, Reepham (Site GNLP0353R). Please find attached response forms, the representations and a Delivery Statement.

SEE ENCLOSED NOTE 3

On behalf of our client, Orbit Homes, we are pleased to submit representations to the Regulation 19 Publication of the Greater Norwich Local Plan (GNLP). The attached letter contains a summary of our client’s representations, the detail of which is contained on the attached enclosures (including required forms).

Please see the section addressing Policy 3 in the attached representations submitted on behalf of the Thelveton Estate in support of the allocation of Land west of Nelson Road, Diss.

We are pleased to submit representations for Pigeon Investment Management Ltd and the landowners in support of Land at Nelson Road, Diss. Please find attached response forms, the representations, a Concept Plan and Landownership Plan.

Please see the section addressing Policy 3 in the attached representations submitted on behalf of the Thelveton Estate in support of the allocation of Land at Walcot Green Lane, Diss.

We are pleased to submit representations for Pigeon Investment Management Ltd and the landowners in support of Land at Walcot Green Lane, Diss. Please find attached response forms, the representations and a Delivery Statement.

To be more effective the Plan needs to be based on a more up to date evidence base and identify more green infrastructure particularly in proximity to large strategic allocations as is the case at Sprowston.

The redevelopment of the site of the Sprowston Sports and Social Club to provide beautiful, high-quality, much needed new homes for older people and open space and play facilities accessible to all. In the form of a public park, would be a much more efficient use of land in keeping with the principles and objectives of the sustainable development expressed in the NPPG, National Planning Policy Framework, GNLP Pre-Submission Draft Strategy and recent government policy requiring all new developments to meet local standards of beauty, quality and design. It would set an example of the high quality, beautifully designed places expected from every development throughout the plan period and beyond.

It would meet the three overarching objectives and purpose of planning; that is, ensuring a more responsive and competitive local economy and coordinating the provision of infrastructure (the economic objective of sustainable development), support strong, vibrant and healthy communities through provision of accessible open spaces where it is needed (the social objective) and through making more efficient use of brownfield land to encourage healthier, more active lifestyles (the environmental objective).

This representation is submitted by Le Ronde Wright on behalf of the Trustees of site at Sprowston Sports and Social Club.

This submission relates to Policy 1, Policy 2 & 3, Policy 5 and paragraphs 275 to 277, and Policy 6. See summaries for detail.

A straightforward solution would be to revise the Reg. 19 draft to align with the Reg. 18 proposals for target housing numbers; justify the job numbers target as realistic, remove the NWL from the plan and tighten up the policies and provide targets for the environment and climate change before submission to the Inspector for approval.

THE FOLLOWING IS AN OFFICER-CREATED SUMMARY OF MR CAWDRON’S REPRESENTATION. THE FULL TRANSCRIPTION IS ALSO ATTACHED

The changes between the Reg18C draft plan and the Reg 19 version include a significant increase in housing numbers, which has not been subject to public consultation. Furthermore, the latest Government advice from December 2020 is that the 2017 method of calculating housing requirement would continue, negating the need for the additional housing and buffer. Using the 2017 method, the projected need for 20 years for Greater Norwich is around 40,000 homes, closely aligning with the Reg18C draft plan. The Norwich Wensum Link should not be included as a legal assessment made in 2016, which is still current, found that the integrity of the SAC would be adversely affected and only relatively little weight would be attached to the need to relieve congestion in the Norwich area. The GNLP attempts to distance itself from the HRA obligations connected to the NWL, which is a project which overrides a legal opinion in 2016. There is no mention of the December 2020 Government carbon target emissions reduction of at least 68% by 2030.
To correct these issues, revise the Reg. 19 draft to align with the Reg. 18 proposals for target housing numbers; justify the job numbers target as realistic, remove the NWL from the plan and tighten up the policies and provide targets for the environment and climate change before submission to the Inspector for approval.

A straightforward solution would be to revise the Reg. 19 draft to align with the Reg. 18 proposals for target housing numbers; justify the job numbers target as realistic, remove the NWL from the plan and tighten up the policies and provide targets for the environment and climate change before submission to the Inspector for approval.

THE FOLLOWING IS AN OFFICER-CREATED SUMMARY OF MR CAWDRON’S REPRESENTATION. THE FULL TRANSCRIPTION IS ALSO ATTACHED

The changes between the Reg18C draft plan and the Reg 19 version include a significant increase in housing numbers, which has not been subject to public consultation. Furthermore, the latest Government advice from December 2020 is that the 2017 method of calculating housing requirement would continue, negating the need for the additional housing and buffer. Using the 2017 method, the projected need for 20 years for Greater Norwich is around 40,000 homes, closely aligning with the Reg18C draft plan. The Norwich Wensum Link should not be included as a legal assessment made in 2016, which is still current, found that the integrity of the SAC would be adversely affected and only relatively little weight would be attached to the need to relieve congestion in the Norwich area. The GNLP attempts to distance itself from the HRA obligations connected to the NWL, which is a project which overrides a legal opinion in 2016. There is no mention of the December 2020 Government carbon target emissions reduction of at least 68% by 2030.
To correct these issues, revise the Reg. 19 draft to align with the Reg. 18 proposals for target housing numbers; justify the job numbers target as realistic, remove the NWL from the plan and tighten up the policies and provide targets for the environment and climate change before submission to the Inspector for approval.

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.

The GNLP is deficient in housing for the elderly, employment land, and the impact on the environment. See rep summaries for detail.

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.

Policy 3 should be adjusted to allow ability to deliver on-site mitigation as an alternative to per dwelling contributions.
SEE FULL REP ATTACHED.

Representation on behalf of Orbit Homes, J Alston and Sons and Pelham Homes in relation to Silfield Garden Village.

The team led by Orbit Homes are generally supportive of the GNLP (Pre-submission) as currently drafted but consider that some aspects of the Pre-submission GNLP would benefit from amendment and/or further detail to ensure the GNLP meets the soundness test as set out at paragraph 35 of the NPPF. Please see the enclosed representation submission for details.

We strongly recommend that Policy 3 and the supporting text are substantially amended and expanded to address the points made in (5) above, together with more comprehensive details and measures including in relation to designated sites and protected landscapes, protected species, climate change adaptation, halting and reversing the loss of biodiversity, recreational disturbance on non-designated sites, Green Infrastructure (GI) networks and suitable alternative greenspace (SANGS).

Despite providing only an elementary level of information, many other Policies repeatedly refer to Maps 8A and 8B, stating that:

"Enhancements to the multi-functional green infrastructure network will be provided by development to contribute to the strategic network as set out in maps 8A and B and to linking local networks."

The Local Plan needs to provide a comprehensive strategic document, rather than Maps 8A and 8B, that sets out how the development proposals in the Plan will contribute to creating new GI, and protecting, expanding or enhancing existing GI, at site level, and across the Plan area, to form a cohesive GI network that delivers multiple benefits for people and the natural environment.

New development should provide environmental net gains in terms of both GI and biodiversity. Proposals should demonstrate how the development would contribute towards new GI opportunities or enhance the existing GI network as part of the development. New development must also secure ecological enhancements as part of its design and implementation, and should provide a biodiversity net gain that is proportionate to the scale and nature of the proposal, and contribute to establishing coherent ecological networks that are more resilient.

To ensure that the policy is compliant with both the NPPF and the Conservation of Habitats and Species Regulations 2017 (as amended) (‘the Habitats Regulations’) we recommend that the following text is added to Policy 3:

"Any development that would be likely to have a significant effect on a European site, either alone or in combination with other plans or projects, will be subject to assessment under the Habitat Regulations at project application stage. If it cannot be ascertained that there would be no adverse effects on site integrity the project will have to be refused or pass the tests of regulation 62, in which case any necessary compensatory measures will need to be secured."

This amendment is also necessary due to the way in which mitigation measures for various designated sites (identified in the Plan’s Habitats Regulations Assessment), have been incorporated into the wording of the relevant policies in the Plan.

We objected to the policy and supporting text in our response to the Reg 18 Consultation (see our letter dated 16 March 2020 (our ref:307463)). We consider that the policy and supporting text are inadequate to protect, maintain, restore and enhance the natural environmental assets of the area. The policy will not ensure the delivery of Green Infrastructure of sufficient quality and quantity in the right locations (contrary to NPPF para 171), nor help the Plan to meet the sustainability criteria or adapt to climate change in a coherent and robust manner. It contains too much uncertainty and needs to explain the hierarchies of site protection and mitigation.

As currently worded, Policy 3:

• does not make it clear that there is a hierarchy of avoiding, mitigating and then compensating significant harm (NPPF para 171);
• does not contain criteria against which any proposed development affecting designated sites will be judged (NPPF para 175);
• does not make clear the distinctions between the hierarchy of designated sites and landscapes so that protection is commensurate with their status and gives appropriate weight to their importance (NPPF para 175 and para 172);
• does not make clear that the sustainable development presumption does not apply where development requiring appropriate assessment is required (NPPF para 177); and
does not make explicit reference to either project level Habitats Regulations Assessments (HRAs), or potential compensatory measures, as being required in relation to those allocations which have likely significant effects on European habitats sites.

Previously we recommended using Policy 1: Addressing climate change and protecting environmental assets in the current Joint Core Strategy (2011) as a basis, since much of this policy is valid under the NNPF and relevant, and suggested 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). Their Local Plan was adopted subsequently in September 2020 with only some minor amendments made to Policy SCLP 10.1.

Please see the section addressing Policy 3 in the attached representations submitted on behalf of the Hethersett Consortium in support of the allocation of Land at Hethersett.

We are pleased to submit representations for Pigeon Investment Management Ltd and the landowners in support of Land at Hethersett. Please find attached response forms, the representations and a Delivery Statement .

Add reference (policy and text) to Historic Landscape Characterisation and Landscape Character Assessments

Thank you for consulting Historic England on the Greater Norwich Local Plan Regulation 19 Draft including The Strategy and The Sites. As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the conservation and enjoyment of the historic environment.

Our comments below should be read with reference to our previous comments dated 1.2.17, 15.3.18, 4.12.1, 26.4.19 and 16.3.20. Please also see our detailed comments in the attached tables, Appendix A in relation to The Strategy and Appendix B regarding The Sites.

SUMMARY
The Greater Norwich Local Plan covers the Strategy and Site Allocations. While commenting on the plan as a whole, Historic England is particularly concerned, for its implications for Norwich itself. Norwich is one of England’s great historic cities, and its architectural and historic character, and the sense of place associated with that, make a profound and wholly beneficial contribution to the city’s well-being.

In line with paragraph 185 of the National Planning Policy Framework (NPPF) it is important that the Plan should set out a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats.

Ensure sound evidence base for the
historic environment in advance of EiP
a) Prepare a topic paper for the historic environment
b) Prepare HIAs for selected sites
c) Prepare taller buildings study to inform strategy
d) Prepare capacity of sites evidence base document

Thank you for consulting Historic England on the Greater Norwich Local Plan Regulation 19 Draft including The Strategy and The Sites. As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the conservation and enjoyment of the historic environment.

Our comments below should be read with reference to our previous comments dated 1.2.17, 15.3.18, 4.12.1, 26.4.19 and 16.3.20. Please also see our detailed comments in the attached tables, Appendix A in relation to The Strategy and Appendix B regarding The Sites.

SUMMARY
The Greater Norwich Local Plan covers the Strategy and Site Allocations. While commenting on the plan as a whole, Historic England is particularly concerned, for its implications for Norwich itself. Norwich is one of England’s great historic cities, and its architectural and historic character, and the sense of place associated with that, make a profound and wholly beneficial contribution to the city’s well-being.

In line with paragraph 185 of the National Planning Policy Framework (NPPF) it is important that the Plan should set out a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats.

See attachment for full representation

On behalf of our client, Fuel Properties (Norwich) Ltd, we provide our comments on the Greater Norwich Plan Pre-Submission Draft Strategy (Regulation 19 Publication Stage), published for consultation in February 2021.

Fuel Properties (Norwich) Ltd are the developers of the Carrow Works site in east Norwich, which is identified in the emerging Greater Norwich Local Plan as being within the East Norwich Strategic Regeneration Area. The wider Regeneration Area has the potential to deliver some 4,000 new homes and 6,000 jobs, and will act as a catalyst for longer term regeneration of the wider area. The Carrow Works site comprises an important and substantial part of the East Norwich Strategic Regeneration Area and provides a significant opportunity to deliver growth for Norwich City the Greater Norwich
area.

Our client welcomes the opportunity to provide comments on the emerging Greater Norwich Local Plan and to work collaboratively with the authority and key stakeholders as the plan progresses.

See attachment for full representation.