Interim Sustainability Appraisal
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Interim Sustainability Appraisal
Interim Sustainability Appraisal
Representation ID: 16421
Received: 22/03/2018
Respondent: Natural England
Natural England is satisfied that the SA objectives, assessment methodology and framework generally accord with the requirements of the Planning and Compulsory Purchase Act 2004 and the Strategic Environmental Assessment Regulations.
HRA
The future conclusions and recommendations of the Habitats Regulations Assessment (HRA) will need to be incorporated into later revisions of the Sustainability Appraisal (SA) report, and be reflected in the allocations and policies of the Local Plan.
Water Cycle Study
Natural England advises that a Water Cycle Study should be completed as soon as possible to provide the evidence required to inform the SA and enable sound judgements to be made regarding which allocations are sustainable and can be taken forward. The SA will not be able to rely alone on the emerging development management policies to mitigate the potential adverse effects of proposals on the natural environment, including designated sites. How the issues of water abstraction and waste water management and treatment capacity will be dealt with through the Plan will be informed by the findings of the Water Cycle Study. Any mitigation measures will need to be secured through relevant allocation policies.
Recreational Disturbance
The issue of additional recreational pressure associated with proposed growth, and measures needed to address this, should be addressed through the SA, having regard to the objectives of the strategic in accordance with GI policies and the Strategic GI Network for Greater Norwich map. The findings of the SA, relating to GI, should be referenced in policies. Mitigation measures identified in the SA should be secured through the relevant site allocation policies together with a clear delivery/funding mechanism.
With regard to GI, we question why the Reasonable Alternative NC3 has not been included in the Growth Options consultation under Q53 as it has the highest positive score of the three options. NC3 states:
NC3 - Broadly reproduce the current JCS Policy 1 elements as they relate to green infrastructure, updating the baseline information (such as the GI Map), with each allocated site setting out the details of any specific mitigation measures/improvements within its allocation policy
We support this approach particularly as it would set out specific mitigation measures for each allocated site where appropriate.
Best and Most Versatile Land
Where no site-specific Agricultural Land Classification (ALC) survey information exists, the Local Plan should specify the need for those proposing sites to undertake a suitable site-specific ALC survey to inform the assessment process. We expect that the site-specific ALC survey data is used to consider the impact on soils through the SA to fully explore the justification for allocating best and most versatile (BMV) land, and ultimately to inform site specification and masterplans. Currently, there is no real consideration of this issue in the Regulation 18 consultation documents.
Natural England is satisfied that the SA objectives, assessment methodology and framework generally accord with the requirements of the Planning and Compulsory Purchase Act 2004 and the Strategic Environmental Assessment Regulations.
HRA
The future conclusions and recommendations of the Habitats Regulations Assessment (HRA) will need to be incorporated into later revisions of the Sustainability Appraisal (SA) report, and be reflected in the allocations and policies of the Local Plan.
Water Cycle Study
Natural England advises that a Water Cycle Study should be completed as soon as possible to provide the evidence required to inform the SA and enable sound judgements to be made regarding which allocations are sustainable and can be taken forward. The SA will not be able to rely alone on the emerging development management policies to mitigate the potential adverse effects of proposals on the natural environment, including designated sites. How the issues of water abstraction and waste water management and treatment capacity will be dealt with through the Plan will be informed by the findings of the Water Cycle Study. Any mitigation measures will need to be secured through relevant allocation policies.
Recreational Disturbance
The issue of additional recreational pressure associated with proposed growth, and measures needed to address this, should be addressed through the SA, having regard to the objectives of the strategic in accordance with GI policies and the Strategic GI Network for Greater Norwich map. The findings of the SA, relating to GI, should be referenced in policies. Mitigation measures identified in the SA should be secured through the relevant site allocation policies together with a clear delivery/funding mechanism.
With regard to GI, we question why the Reasonable Alternative NC3 has not been included in the Growth Options consultation under Q53 as it has the highest positive score of the three options. NC3 states:
NC3 - Broadly reproduce the current JCS Policy 1 elements as they relate to green infrastructure, updating the baseline information (such as the GI Map), with each allocated site setting out the details of any specific mitigation measures/improvements within its allocation policy
We support this approach particularly as it would set out specific mitigation measures for each allocated site where appropriate.
Best and Most Versatile Land
Where no site-specific Agricultural Land Classification (ALC) survey information exists, the Local Plan should specify the need for those proposing sites to undertake a suitable site-specific ALC survey to inform the assessment process. We expect that the site-specific ALC survey data is used to consider the impact on soils through the SA to fully explore the justification for allocating best and most versatile (BMV) land, and ultimately to inform site specification and masterplans. Currently, there is no real consideration of this issue in the Regulation 18 consultation documents.
