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Site Proposals document

Representation ID: 16480

Received: 20/03/2018

Respondent: Norfolk Wildlife Trust


0469 and 0251 should be recognised as having CWS or priority habitat constraint. There should be no development on CWS and should be a buffer to CWS.

Full text:

General comments:
All allocations need to be considered in relation to the Greater Norwich GI Strategy and the emerging Norfolk GI maps, in relation to both opportunities and constraints.
As for previous consultations, our comments on site allocations relate to information that we hold. This relates mainly to impacts on CWS. These comments are in addition to previous pre-consultation comments on potential allocations. However, we are not aware of all impacts on priority habitats and species, or on protected species and further constraints may be present on some proposed allocations. Similarly, we have flagged up impacts on GI corridors where this is related to CWS but there should be an assessment of all proposed allocations against the emerging GI maps for Norfolk, which should consider both locations where allocations may fragment GI and areas within allocations that could enhance GI network. As a result, lack of comment on sites does not necessarily mean that these are supported by NWT and we may object to applications on allocated sites, if biodiversity impacts are shown to be present?

We are aware that the GNLP process will be taking place at the same time as Natural England work on licensing with regard to impacts of development on great-crested newt. This work will include establishment of zones where development is more or less likely to impact on great-crested newt. We advise that this ongoing work is considered as part of the evidence base of the GNLP, if practicable to do so in the time scale.

0265 There is a substantial block of mature trees within this proposed allocation which we understand provides nesting site for common buzzard and is part of wooded ridge. Although not protected under schedule 1 of the Wildlife & Countryside Act, in our view this should be seen as a constraint on development and wooded ridge should be protected.

0290: In our view development within the Drayton Woods CWS is not acceptable and this site should not be allocated.
We agree with constraints due to proximity to CWS that are assessed for other proposed allocations in Drayton

0492 we are pleased to see that impact on CWS is recognised as a major constraint and the need for area within CWS to be recognised as GI, if there is any smaller development outside of CWS

Adjacent CWS represents a potential constraint as has been recognised.

We note that the presence of CWS and river valley are recognised as constraints, although assessment is that impacts on these areas can be avoided by becoming green space in a larger development. If taken forward, plans would need to include a buffer to all CWS and assessment of biodiversity value of each CWS to establish whether they have particular sensitivity. At this stage, NWT take view that 0415 should not be allocated, even if part of a large development.

0469 and 0251 should be recognised as having CWS or priority habitat constraint. There should be no development on CWS and should be a buffer to CWS.

0571 This would be a new settlement and we are pleased to see that a biodiversity constraint is recognised. However, Witton Run is a key GI corridor linking to Broads National Park. It is essential that impacts on GI corridors, such as Witton Run, are recognised even when not made up of designated sites, if the Greater Norwich GI strategy is to have any value.

1007: This is STW expansion. If expansion is necessary at this STW, there will need to be mitigation and/or compensation with regard to impacts on CWS
1006: There are potential impacts on CWS 1365, which need to be considered

0132 We are pleased to see that GI constraints and opportunities are recognised. However, need to ensure that allocation allows for protection and enhancement of GI corridor.

0563: Recognition of impact on CWS is recognised but need to ensure no development within CWS, plus buffer to the CWS, if this is taken forward.
0337: Buffer to Marriott's Way CWS needs to be recognised

Thorpe St Andrew:
0228 and 0442: Pleased to see that the impact on CWS 2041 and GI corridor seen as a major constraint and that all sites proposed will have an adverse impact. These sites should not be allocated.

Deal ground 0360: Previous permissions allow for protection and enhancement of Carrow Abbey Marsh CWS. There is great potential for restoration of this CWS as a new nature reserve, associated with the development and a key area of GI linking the city with Whitlingham Park. This aim should be retained in any renewal of the allocation and new permissions

0068: Development should not reach up to riverside but allow for creation of narrow area of natural bankside semi-natural vegetation to link with similar between adjacent river and Playhouse. This will help to deliver the (Norwich) River Wensum Environment Strategy

South Norfolk

0416: We are pleased to see that biodiversity constraints are recognised but there is a need to mitigate for impacts on adjacent CWS 2216 though provision of buffer.
1013: There are potential biodiversity constraints, with regard to semi-natural habitats

0210: We are pleased to see that impacts on CWS, existing woodland and protected species seen as major constraint.

1032: There may be biodiversity constraint in relation to habitats on site

Bracon Ash:
New settlement 1055: We are pleased to see that affects CWS and priority habitats are recognised. There is potential for significant additional impact on Ashwellthorpe Wood SSSI. This site is open to the public but is sensitive and not suitable for increased recreational impacts, owing to the wet nature of the soils and the presence of rare plants, which are sensitive to trampling. We are also concerned about increased recreational impacts on of a new settlement on Lizard and Silfield CWS and on Oxford Common. These sites are already under heavy pressure owing to new housing in South Wymondham. Unless impacts can be fully mitigated we are likely to object to this allocation if carried forward to the next stage of consultation.

0346: We are pleased to see recognition of constraints relating to adjacent Broome Heath CWS

0485: see Poringland

1014: There may be biodiversity constraints with regard to adjacent stream habitats

0253: Constraints relating impacts on existing CWS 235 and impacts on floodplain may be significant and should also be recognised as factors potentially making this allocation unsuitable for the proposed development

0238: We are pleased to see constraints in relation to CWS and flood risk are recognised.
0266: We are pleased to see constraints recognised. The value of parts of this porposed allocation as a GI corridor need to be considered.
0489: We are pleased to see that constraints relating to river valley CWS recognised. This site should not be allocated

0461: The whole of 0461 consists of semi-natural habitat, woodland and grazed meadow and should not be allocated for development. In addition adjacent land in the valley bottom is highly likely to be of CWS value and should be considered as such when considering constraints
0244: This site is currently plantation woodland and part of the Yare Valley GI corridor. It should not be allocated, for this reason

We support the recognition that constraints regarding to biodiversity need to be addressed. Contributions to GI enhancement should be considered. 1004, 1044 & 1045 may cause recreational impact on CWS 2286 (Frenze Brook) and mitigation will be required.

0177: We are concerned that constraints with regard to impacts on CWS 2132 and 233 are not recognised. These two CWS require continued grazing management in order to retain their value and incorporation as green space within amenity green space is not likely to provide this. Development of the large area of 0177 to the south of the Norwich Road would provide an opportunity for habitat creation and restoration

0415: We are concerned with the biodiversity impacts of development along Yare Valley and on CWS and habitats on the valley slopes (including CWS in Barford parish). If this area is allocated it should only be as a semi-natural green space that is managed as semi-natural habitat

0485: We are pleased to see recognition of constraints relating to CWS. Any country park development should ensure continued management and protection of

0526: There is potential for recreational impacts on Roydon Fen CWS. This impact needs to be considered for all proposed allocations in Roydon and if taken forward mitigation measures may be required. We are also concerned about water quality issues arising from surface water run-off to the Fen from adjacent housing allocations and these allocations should only be taken forward if it is certain that mitigation measures can be put in place. Roydon Fen is a Suffolk Wildlife Trust nature reserve and SWT may make more detailed comments, with regard to impacts.
Although appearing to consist mainly of arable fields this 3-part allocation contains areas of woodland and scrub, which may be home to protected species. These areas should be retained if this area is allocated and so will represent a constraint on housing numbers.

Toft Monks:
0103: We are pleased to see that a TPO constraint recognised and value as grassland habitat associated with trees should be considered.

0150: Buffer to CWS could be provided by GI within development if this allocation is taken forward.
1009: Impacts on CWS 94 may require mitigation.

Current allocations in Wymondham have already led to adverse impacts on CWS around the town, through increased recreational pressure. Although proposals for mitigation are being considered via Wymondham GI group, further development south of town is not possible without significant GI provision. This applies particularly to 0402. Similarly, there is very limited accessible green space to the north of the town and any development will require significant new GI. 0354 to north of town includes CWS 215, which needs to be protected and buffered from development impacts and CWS 205 needs to be protected if 0525 is allocated.