Draft Greater Norwich Local Plan – Part 1 The Strategy

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Object

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 2: Is the overall purpose of this draft plan clear?

Representation ID: 21708

Received: 16/03/2020

Respondent: RSPB (East of England Regional Office)

Representation:

No. The content describes relationships between adjacent planning authorities within the context of housing development. The integration between these authorities and local plans should be made clear beyond housing, for example how increased development within one plan area might lead to increased recreational pressure within another area. Examples might include provision of electric vehicle charging points at the start and end of journeys combined with information to promote enjoyable experiences at that end point.

Full text:

No. The content describes relationships between adjacent planning authorities within the context of housing development. The integration between these authorities and local plans should be made clear beyond housing, for example how increased development within one plan area might lead to increased recreational pressure within another area. Examples might include provision of electric vehicle charging points at the start and end of journeys combined with information to promote enjoyable experiences at that end point.

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 5: Is there anything you feel further explanation, clarification or reference?

Representation ID: 21714

Received: 16/03/2020

Respondent: RSPB (East of England Regional Office)

Representation:

Greater detail is required on resource management through the Local Plan. The HRA needs to be revised to fully reflect the importance of the area and not rely on reports that have not yet been finalised.

Full text:

Paragraph 98 describes the need to maintain water quality to prevent damage to protected sites. This statement needs further clarification and the statements in paragraphs 106 and 107 should be further qualified to mention the potential conflict between maintaining river flows and ensuring no adverse impact on protected sites and species; and the need as a public water supply.

In paragraph 105 the focus seems to be on soil management for agricultural purposes with Map 6 showing a solely agricultural perspective. No mention is made of the impact of poor soil management on the riparian habitats. Equally mention needs to made of the value of the peat and chalk soils especially in the Wensum valley and the role of peat soils in capturing carbon.
It is difficult to comment on statements as described in paragraph 107 where mention is made of the area being categorised as suffering from serious water stress and solutions to overcome this state being managed by another company and another plan, the details of which are not available. Clarification is needed to describe the mechanisms by which serious water stress will be overcome

Paragraph 98 states that the GNLP will need to ensure development does not have a negative impact on designated sites but does not offer any further detail as to how this will be achieved. This lack of detail makes it difficult to provide constructive comments to improve the quality of the plan and facilitate successful delivery.

Paragraph 101 mentions long-term work is being undertaken to improve green infrastructure, but no further detail or is provided. Providing this information will help us to provide constructive comments to improve the quality of the plan and facilitate successful delivery.

Paragraph 101 also mentions providing biodiversity buffer zones as a means of controlling the impact on protected areas. This statement contradicts the findings described within the Habitats Regulation Assessment which categorically states there will be no adverse impact on protected habitats and protected species.

As a point of detail, the HRA should describe the impact of the activity in terms of ‘likely significant effect.’

Another failing of the HRA is its consideration of potential sources of impact on designated sites and designated species in isolation. RSPB has shown that a combination of impact sources leads to damaging events on sites and species.

We suggest the HRA needs further work to incorporate this ‘in combination’ aspect.

People will naturally gravitate to the best parts of the countryside, often next to rivers with views. Mitigation is needed to cover the cost of deterioration of infrastructure at these locations, as well as enhancing facilities and their management and promoting sustainable access.

Paragraph 104 describes policies to protect landscapes but provides no further explanation as to what the mechanisms are by which this will be achieved. It is hard to understand and comment on potential negative or positive impact without any detailed information.

Paragraph 107 makes the statement increased efficiency in water and energy use will have minimised the need for new infrastructure but neglects to describe there is still the basic need to extract from source. This comment aligns with our comment 4. above. Additionally, we would suggest that protection of the water resource and water quality goes beyond new water efficient buildings and these form only a fraction of the existing residential and commercial building resource. How will the lessons learnt from the new build be conveyed and implemented across existing infrastructure to help change failing Water Framework Directive status of rivers and water bodies in the Broads?

Additional increased growth will compound existing issues around water provision, water quality, Nitrogen and ammonium deposition.

Figure 4 does not show the marine protected areas off the Norfolk Coast. As a minimum, the Outer Thames Estuary SPA and Greater Wash SPA should be identified. This is important when considering in-combination assessments in the HRA, as features of these sites that breed on beaches could be impacted by increased recreational pressure from new development within Greater Norwich.

Support

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 6: Do you support or object to the vision and objectives for Greater Norwich?

Representation ID: 21722

Received: 16/03/2020

Respondent: RSPB (East of England Regional Office)

Representation:

The RSPB supports the general principles but is disappointed by the lack of ambition with respect to the timescale for achieving net zero emissions.

Full text:

Yes, the RSPB supports the principles outlined, but is difficult to provide specific comments due to the lack of detail provided. We support calls for greater aspiration with respect to achieving net zero emissions as early as possible (i.e. before 2050) and more stringent water targets. If Norfolk County Council has adopted steps for their assets to be carbon neutral by 2030 (as highlighted in footnote 51 of the Strategy Document, p.40) surely this should be applied to new development in the Greater Norwich area as a minimum and 2038 (i.e. the end of the plan period) as a maximum? We urgently to take steps as quickly as possible to tackle the climate crisis. Nature has a major role to play and the GNLP has a key role in championing nature-based solutions. The RSPB would be happy to be part of conversations to explore this approach.

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 7: Are there any factors which have not been covered that you believe should have been?

Representation ID: 21725

Received: 16/03/2020

Respondent: RSPB (East of England Regional Office)

Representation:

More detail is required to on the type of measures required by the Council's to achieve net zero and protect the environment to determine if they will be effective and ensure the plan will be sound.

Full text:

Paragraph 126 highlights the future modes of transport. We suggest the plan needs to be considered in collaboration with plans for adjacent authorities such that facilities (such as charging points for electric vehicles) are provided at the start and end of a journey, with information promoting an enjoyable experience. This could align with provision of charging points in rural areas/hotspots.

Paragraph 133 describes making improvements to and linking habitats as a means of helping communities mitigate for and adapt to climate change, but no mention is made of what these habitats are and where connections will be made. In order to allow comment these points need to be described. Tree planting at scale in the right locations to capture carbon, SuDS to cope with surface water run-off, collection reservoirs within developments providing a source of grey water leading to reduced demand. The scale of ambition should be outlined, even if the details need to work out in Supplementary Planning Documents.

A fuller description needs to be provided showing how access to the countryside have been improved/provided and which, where and how will the quality of environmental assets have been achieved? How will decisions be made when selecting where to improve?

Mention is made of protecting the environment but the focus in the plan is on new build. The greatest level of beneficial impact/change would be realised in existing housing and infrastructure with poor quality build characteristics. What is the link between new and old? What plan is to be in place to apply lessons learned from new build to, for example, retrofit or upgrade? The Local Plan needs to focus on improving existing development if it is to support carbon neutrality.

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 8: Is there anything that you feel needs further explanation, clarification or reference

Representation ID: 21727

Received: 16/03/2020

Respondent: RSPB (East of England Regional Office)

Representation:

As per comments in question 6, the objects as written come across more as aspirations than objective statements. We recommend a tabular representation showing how the objectives link to outcomes and outputs. Objectives are best understood and conveyed when they are SMART – specific, measurable, achievable, realistic and time-bound, otherwise they are just aspirational statements. The RSPB would be happy to discuss options and help shape this element of the plan.

Full text:

As per comments in question 6, the objects as written come across more as aspirations than objective statements. We recommend a tabular representation showing how the objectives link to outcomes and outputs. Objectives are best understood and conveyed when they are SMART – specific, measurable, achievable, realistic and time-bound, otherwise they are just aspirational statements. The RSPB would be happy to discuss options and help shape this element of the plan.

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 12: Do you support, object, or have any comments relating to the Climate Change Statement?

Representation ID: 21730

Received: 16/03/2020

Respondent: RSPB (East of England Regional Office)

Representation:

The focus of the Climate Change statement is mostly on carbon impacts resulting from climate change. There is no mention of how increased water demands combined with drier, hotter summers will lead to reduced flows in rivers and the potential impact on both the water resource (in terms of quantity and quality), and protected habitats

Has thought been given to construction of a large storage reservoir as a water supply with multiple use benefits e.g. recreation and biodiversity buffer, potential source for irrigation of arable crops? Greater aspiration will be required if climate targets are to be realised.

Full text:

The focus of the Climate Change statement is mostly on carbon impacts resulting from climate change. There is no mention of how increased water demands combined with drier, hotter summers will lead to reduced flows in rivers and the potential impact on both the water resource (in terms of quantity and quality), and protected habitats

Has thought been given to construction of a large storage reservoir as a water supply with multiple use benefits e.g. recreation and biodiversity buffer, potential source for irrigation of arable crops? Greater aspiration will be required if climate targets are to be realised.

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 14: Do you support, object or wish to comment on the approach for housing numbers and delivery?

Representation ID: 21733

Received: 16/03/2020

Respondent: RSPB (East of England Regional Office)

Representation:

Paragraph 144 places an emphasis is on providing for future human generations. There is a need to place the same value on nature which fulfils its own function, not just one for humans to enjoy and appreciate.

Full text:

Paragraph 144 places an emphasis is on providing for future human generations. There is a need to place the same value on nature which fulfils its own function, not just one for humans to enjoy and appreciate.

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 14: Do you support, object or wish to comment on the approach for housing numbers and delivery?

Representation ID: 21753

Received: 16/03/2020

Respondent: RSPB (East of England Regional Office)

Representation:

There needs to be a clearer link made with The Broads to demonstrate that additional pressures from the Greater Norwich plan will be appropriately managed.

Full text:

The map shows housing allocation in the Growth Triangle is proximate to Broads National Park. How will the impact of proposals within GNLP area be balanced and aligned with those in adjacent, separate (in terms of strategic planning oversight) areas?
There will likely be an increase in pressure on facilities within the Broads National Park as a result of residents from new developments, leading to increased disturbance on designated species (this disagrees with HRA findings), and increased wear and tear on infrastructure. How will the tariff system proposed be managed and funds allocated to provide for example vehicle charging points, repair of trails, gates etc within outside of the GNLP area. The Greater Norwich area can’t be viewed in isolation to surrounding areas managed by other authorities.
The RSPB is disappointed that HRA conclusions suggest the plan will be sound as there will not be any adverse effects on integrity of Natura 2000 and Ramsar sites, but in several areas this is due to reliance on plans that have not yet been completed such as the Norfolk RAMS and GI Strategy. Until such plans and approaches are finalised, they cannot be relied upon and cannot be taken to as a measure to demonstrate that the GNLP policies will be sound. The RSPB looks forward to seeing revised HRA recommendations based on an evidence base that is final and has certainty that it will be in place by the time the plan is adopted.

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 18: Do you support, object or have any comments relating to the preferred approach to sustainable communities including the requirement for a sustainability statement?

Representation ID: 21762

Received: 16/03/2020

Respondent: RSPB (East of England Regional Office)

Representation:

Careful consideration of water impacts (quality and quantity) will be required to demonstrate that there definitely will not be any adverse effects on integrity of Natura 2000 and Ramsar sites.

Full text:

Good to see a more rigorous approach being applied to water management and adopting more demanding standards. Although the GNLP focuses on new build (as mentioned in comment 13 above related to paragraph 107) what additional benefits could be gained from improvements to existing residential and commercial buildings?
Given water is such a vital resource and comments have been made regarding the serious water stress status of the area, how successful has Anglian Water’s ‘love every drop’ campaign been and do they propose continuance and escalation of this approach?
A fully updated and signed off water cycle study will be required to inform decisions about what is appropriate. This will be necessary to inform HRA conclusions and ensure that adverse effects on integrity will be avoided.
The RSPB is disappointed that HRA conclusions suggest the plan will be sound as there will not be any adverse effects on integrity of Natura 2000 and Ramsar sites, but in several areas this is due to reliance on plans that have not yet been completed such as the Norfolk RAMS and GI Strategy. Until such plans and approaches are finalised, they cannot be relied upon and cannot be taken to as a measure to demonstrate that the GNLP policies will be sound. The RSPB looks forward to seeing revised HRA recommendations based on an evidence base that is final and has certainty that it will be in place by the time the plan is adopted.

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 21: Do you support, object or have any comments relating to the approach to the natural environment?

Representation ID: 21766

Received: 16/03/2020

Respondent: RSPB (East of England Regional Office)

Representation:

More detail is needed to demonstrate net gain and to ensure a robust in-combination assessment is undertaken in the HRA.

Full text:

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.

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