Site Proposals document

The site at Racecourse Plantations - Ref: GNLP0442 has been assessed in the Site Proposals Document and at paragraph 3.38 (Thorpe St. Andrew).

The Site Proposals Document states (page 98):

"The other submitted sites, GNLP0228 and 0442, are heavily constrained, chiefly by their ecological value and the County Wildlife Site status of Thorpe Woodlands."

We strongly disagree that the site is"heavily constrained" as a result of its designation as a County Wildlife Site, as suggested in the assessment in the Greater Norwich Local Plan documents.

During the planning application process in relation to the proposal for the erection of up to 300 new homes and the creation of a new community woodland park (Broadland Council ref 20161896), technical assessments of the site were undertaken by ecology experts to understand and assess the impacts the proposed development would have on the site, in particularly in ecological terms. The Technical Ecology Report (appendix 02 submitted via email) demonstrated that the proposal, far from resulting in ecological harm, would actually create ecological benefits.

Importantly, this includes a fundamental change from the current commercial forestry management and paintball and archery activities, which are not sympathetic to the site's existing biodiversity values, to one with a specific ecological focus where nature conservation is paramount. In doing so, the proposal seeks to enhance the County Wildlife Site to achieve a long-term maintenance or enhancement of the local biodiversity baseline.

In terms of protected animal species interests and sensitivities, the key species across the three plantations are birds, bats and herpetofauna - notably great crested newt and grass snake. Species survey work indicates that the proposed development area within Racecourse Plantation is of relatively limited protected species interest (lower sensitivity) compared to woodland areas beyond the development site.

The proposed development area has, therefore, in terms of its overall scale and location, avoided the most valuable and sensitive habitats, and areas of greatest protected animal species interest.

The proposal for this site also includes a Community Woodland Park which seeks to contribute to a multifunctional green infrastructure network, in line with Policy GT2 of the Growth Triangle Area Action Plan, that recognises the importance of the site as a hub within a network of routes, through including areas of retained woodland and trees, open space, swales, wildlife resources and effective linkages between them including connections to adjoining areas. The management of the Community Woodland Park will provide for the long-term maintenance of the green infrastructure network.

This position is strengthened by the finding of the Secretary of State who confirmed (on 6 September 2016) that the proposal was not EIA development (see appendix 03 submitted via email). In doing so, he noted that the site is not within a sensitive area and does not enjoy any statutory protection in terms of landscape, heritage or importance to protected species. A significant environmental effect in relation to the County Wildlife Site was not considered likely, and that in cumulation with other developments nearby this development would not affect populations of protected species to the extent that a significant environmental effect is likely.

We therefore disagree with this assessment within the Site Proposals Document and consider the site Ref: GNLP0442 to be a suitable and sustainable location for residential development and the provision of a country wildlife park, and would create ecological benefits to the site.