Draft Greater Norwich Local Plan – Part 1 The Strategy
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Draft Greater Norwich Local Plan – Part 1 The Strategy
Question 5: Is there anything you feel further explanation, clarification or reference?
Representation ID: 21829
Received: 16/03/2020
Respondent: Natural England
Information provided under ‘The natural environment’ section needs to be improved and expanded as it currently is unclear or incomplete. It needs to recognise and include the issues that the natural environment, both within and adjoining the Plan area, is facing including biodiversity loss, climate change, habitat fragmentation, pollution etc and how the proposed Plan may impact on and address these issues. Currently, it could be read as the only issues facing our natural environment are those identified under (98), which is clearly not the case.
(97) Under (97) and throughout the Local Plan all references to ‘Natura 2000 sites’ should be replaced with ‘European Sites’ since Britain has left the European Union. It would be helpful to explain that in the National Planning Policy Framework (NPPF) these are referred to as ‘habitats sites’ as it is unclear from the text and Map 4 Major Habitat Sites in Norfolk nor are the abbreviations in the legend on the map explained. In addition to Map 4, a separate map (or series of maps) should be included which clearly illustrate the other natural environmental assets found within or adjacent to the GNLP area.
(98) This section needs to be expanded and made clearer with the impacts resulting from growth on water quality and water resources separated from recreational disturbance impacts. The Plan needs to recognise that recreational disturbance impacts affect not just internationally designated sites, but a wide range of other sites that are important for wildlife, including County Wildlife Sites (CWS).
(101) It needs to be clearly stated here that the existing green infrastructure (GI) network needs to be protected from further loss and severance, as well as new GI being created. Mention should also be made of the vital role of GI in:
supporting biodiversity
combating climate change
reducing pollution
helping to create attractive homes and places to work
enhancing landscapes
reducing flood risk, and
contributing to wellbeing
The Plan needs to recognise that the protection and delivery of quality GI is key to delivering many of its objectives and growth cannot be regarded as being sustainable without this. In particular the Local Plan should promote the delivery of a strategic green infrastructure network that is resilient to the scale of development proposed, capable of protecting designated sites and supporting habitat, and delivering the wider range of environmental services to meet development needs.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
We support Broadland District, Norwich City and South Norfolk Councils’ preparation of a joint Local Plan to ensure a consistent approach to planning across the Greater Norwich area, with policies aligned with the revised National Planning Policy Framework (NPPF).
We have made detailed comments in this letter in relation to the following Greater Norwich Local Plan (GNLP) consultation documents:
Draft Local Plan – Part 1 The Strategy
Draft Sites Document
Habitats Regulations Assessment of GNLP, December 2019
Sustainability Appraisal and Strategic Environmental Assessment, January 2020
Natural England acknowledges that the findings of supporting documents including the draft Greater Norwich Water Cycle Study (WCS) (AECOM 2019) and the emerging Green Infrastructure and Recreational Impact Avoidance and Mitigation Strategy (GIRAMS) will need to be incorporated in the policies of the Local Plan and supporting documents, once these are finalised.
To summarise our response briefly, we broadly welcome the progress and development of aspects of the Local Plan and supporting documents to date, though Natural England is not yet satisfied that the relevant Plan polices will provide sufficient mitigation to ensure that there will be no adverse impacts to designated sites alone, and in-combination, through changes in water quality and resources and in regard to recreational disturbance, and to demonstrate that policies are sustainable.
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: 21830
Received: 16/03/2020
Respondent: Natural England
For the Local Plan to deliver actual sustainable development and significantly address climate change, the vision needs to be better balanced. Otherwise, the vision as set out in (109) - (111) appears to be heavily focussed on growth at the expense of the other two pillars of sustainable development.
In our response (dated 21 March 2018 ref:235617) to a previous consultation on the Local Plan, we considered that the vision would be improved by the inclusion of the following words under (110):
‘… and an a protected and enhanced environment’.
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We maintain that this wording is important to include as it sets the tone for the Local Plan and signals the commitment of the local authorities to safeguard their natural assets.
We also consider that under (110) the text should be amended as follows:
‘Growth will make the best of Greater Norwich’s distinct built, natural and historic assets whilst protecting and enhancing them.’
In relation to the Plan’s objectives, Natural England expects GI to feature prominently in the objectives as it has a crucial role in delivering the following objectives: economy, communities, homes, infrastructure and environment and as highlighted in our comments to (101) above. We strongly recommend that the text is amended to reference GI under each of the objective headings (112) – (134) as well as in the wording of these objectives as listed under (135).
We emphasised the role and importance of GI in the new Local Plan in our previous consultation response and would like to re-emphasise its importance in this response. Unless GI is given central prominence in the policies, which need to clearly explain in detail how and where GI will be delivered and the timescale for it, the Plan is unlikely to deliver sustainable development, or adaptation to the impacts of climate change, across the Greater Norwich area.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
We support Broadland District, Norwich City and South Norfolk Councils’ preparation of a joint Local Plan to ensure a consistent approach to planning across the Greater Norwich area, with policies aligned with the revised National Planning Policy Framework (NPPF).
We have made detailed comments in this letter in relation to the following Greater Norwich Local Plan (GNLP) consultation documents:
Draft Local Plan – Part 1 The Strategy
Draft Sites Document
Habitats Regulations Assessment of GNLP, December 2019
Sustainability Appraisal and Strategic Environmental Assessment, January 2020
Natural England acknowledges that the findings of supporting documents including the draft Greater Norwich Water Cycle Study (WCS) (AECOM 2019) and the emerging Green Infrastructure and Recreational Impact Avoidance and Mitigation Strategy (GIRAMS) will need to be incorporated in the policies of the Local Plan and supporting documents, once these are finalised.
To summarise our response briefly, we broadly welcome the progress and development of aspects of the Local Plan and supporting documents to date, though Natural England is not yet satisfied that the relevant Plan polices will provide sufficient mitigation to ensure that there will be no adverse impacts to designated sites alone, and in-combination, through changes in water quality and resources and in regard to recreational disturbance, and to demonstrate that policies are sustainable.
Support
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: 21831
Received: 16/03/2020
Respondent: Natural England
We welcome the Climate Change Statement and support the measures outlined in Table 5 GNLP coverage of climate change issues and recognition of the importance of GI in helping to achieve this. In addition to identifying which Plan policies support this issue, it would be useful to identify any aspects of policies which contribute to the opposite effect, and how these can be modified to help decarbonise future development, and therefore contribute to addressing climate change.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
We support Broadland District, Norwich City and South Norfolk Councils’ preparation of a joint Local Plan to ensure a consistent approach to planning across the Greater Norwich area, with policies aligned with the revised National Planning Policy Framework (NPPF).
We have made detailed comments in this letter in relation to the following Greater Norwich Local Plan (GNLP) consultation documents:
Draft Local Plan – Part 1 The Strategy
Draft Sites Document
Habitats Regulations Assessment of GNLP, December 2019
Sustainability Appraisal and Strategic Environmental Assessment, January 2020
Natural England acknowledges that the findings of supporting documents including the draft Greater Norwich Water Cycle Study (WCS) (AECOM 2019) and the emerging Green Infrastructure and Recreational Impact Avoidance and Mitigation Strategy (GIRAMS) will need to be incorporated in the policies of the Local Plan and supporting documents, once these are finalised.
To summarise our response briefly, we broadly welcome the progress and development of aspects of the Local Plan and supporting documents to date, though Natural England is not yet satisfied that the relevant Plan polices will provide sufficient mitigation to ensure that there will be no adverse impacts to designated sites alone, and in-combination, through changes in water quality and resources and in regard to recreational disturbance, and to demonstrate that policies are sustainable.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Question 17: Do you support, object or wish to comment on the approach to Infrastructure?
Representation ID: 21832
Received: 16/03/2020
Respondent: Natural England
The current wording of the policy needs to be strengthened with regard to the environment and the delivery of GI. Currently it is rather vague and weak with regard to the essential role that quality GI must play if sustainable development is to be delivered under the Plan and meet the needs and aims as set out in the accompanying text under (144). The policy needs to cross reference Policy 3 in order to provide a strong and clear steer of what will be required to deliver the growth strategy whilst protecting and enhancing the area’s natural environmental assets, and to make the Plan sound. We recommend that the wording of the policy needs to be amended as follows (or a similar form of wording used):
“Sustainable development and inclusive growth are supported by…
supporting infrastructure will be provided in line with policies 2, 3 and 4;
environmental protection and enhancement measures including further improvements to the green infrastructure network will be delivered in line with policy 3.”
and:
“INFRASTRUCTURE
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The sustainable growth strategy will be supported by improvements to the transport system, green infrastructure and services. Improvements to existing green infrastructure and the creation of new green infrastructure will be delivered in line with policy 3.”
Whist we welcome recognition that new development must be supported by additional infrastructure of all kinds, in terms of GI, the reference to Appendix 1 is disappointing, given the complete absence of GI being mentioned in Appendix 1. The appendix is based on the findings of the undated Greater Norwich Local Plan Infrastructure Needs Report (GNLPINR). The GNLPINR make very limited reference to the provision of GI via a large scale map which shows strategic GI corridors and contains two sentences.
We strongly recommend that references to GI throughout the Plan should be made instead to the Greater Norwich Infrastructure Plan (dated July 2019). This document refers to GI in many sections, and in Appendix A – Infrastructure Frameworks includes a detailed list of the GI projects that will be delivered under the current Joint Core Strategy (JCS), and presumably rolled forward into the new Plan. Clearly, it will need to be updated due to the new development being proposed under this consultation. However, more detailed information about the quality and quantity of GI together with where on the ground it will be delivered needs to be included in the Plan.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
We support Broadland District, Norwich City and South Norfolk Councils’ preparation of a joint Local Plan to ensure a consistent approach to planning across the Greater Norwich area, with policies aligned with the revised National Planning Policy Framework (NPPF).
We have made detailed comments in this letter in relation to the following Greater Norwich Local Plan (GNLP) consultation documents:
Draft Local Plan – Part 1 The Strategy
Draft Sites Document
Habitats Regulations Assessment of GNLP, December 2019
Sustainability Appraisal and Strategic Environmental Assessment, January 2020
Natural England acknowledges that the findings of supporting documents including the draft Greater Norwich Water Cycle Study (WCS) (AECOM 2019) and the emerging Green Infrastructure and Recreational Impact Avoidance and Mitigation Strategy (GIRAMS) will need to be incorporated in the policies of the Local Plan and supporting documents, once these are finalised.
To summarise our response briefly, we broadly welcome the progress and development of aspects of the Local Plan and supporting documents to date, though Natural England is not yet satisfied that the relevant Plan polices will provide sufficient mitigation to ensure that there will be no adverse impacts to designated sites alone, and in-combination, through changes in water quality and resources and in regard to recreational disturbance, and to demonstrate that policies are sustainable.
Support
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: 21833
Received: 16/03/2020
Respondent: Natural England
We welcome the production of Table 8 – Key Issues addressed by policy 2 and agree with the issues covered.
In relation to issue 3.Green infrastructure it is appropriate for developments to be required to deliver GI off-site, or to financially contribute to this, where it is not possible to deliver quality GI which meets the needs of the inhabitants within that site. It would be useful to state here that development is expected to avoid loss or severance of existing GI networks, and to contribute to the enhancement and extension of existing GI on-site in order to strengthen these networks.
With regard to issue 9. Water the findings of the draft WCS should be referred to, and used to update the table text. A clear intention to adopt the higher standard for water of 110 litres per person per day needs to be stated in the policy. Mention is made of the need to retrofit existing housing and employment stock with water efficiency measures, which we support, and recommend that the Plan should contain a policy which supports this measure.
We support the production of a Sustainability Statement for major developments.
Q19. Do you support, object or have any comments relating to the specific requirements of the policy?
We warmly welcome and support this policy.
Under (3) we consider the provision of accessible GI for recreational uses should be included within the policy. This is necessary to help mitigate the impacts of additional recreational pressure from new housing development on designated sites.
Under (9) we endorse the adoption of the higher standard for water efficiency under the Building Regulations, which is also supported by evidence in the WCS. Reference to retrofitting existing buildings with water efficiency measures has also been as identified as essential in the WCS in terms of managing water demand. We suggest it would be appropriate to include some wording in this policy which recognises this need, and supports its implementation should Government adopt this approach in future.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
We support Broadland District, Norwich City and South Norfolk Councils’ preparation of a joint Local Plan to ensure a consistent approach to planning across the Greater Norwich area, with policies aligned with the revised National Planning Policy Framework (NPPF).
We have made detailed comments in this letter in relation to the following Greater Norwich Local Plan (GNLP) consultation documents:
Draft Local Plan – Part 1 The Strategy
Draft Sites Document
Habitats Regulations Assessment of GNLP, December 2019
Sustainability Appraisal and Strategic Environmental Assessment, January 2020
Natural England acknowledges that the findings of supporting documents including the draft Greater Norwich Water Cycle Study (WCS) (AECOM 2019) and the emerging Green Infrastructure and Recreational Impact Avoidance and Mitigation Strategy (GIRAMS) will need to be incorporated in the policies of the Local Plan and supporting documents, once these are finalised.
To summarise our response briefly, we broadly welcome the progress and development of aspects of the Local Plan and supporting documents to date, though Natural England is not yet satisfied that the relevant Plan polices will provide sufficient mitigation to ensure that there will be no adverse impacts to designated sites alone, and in-combination, through changes in water quality and resources and in regard to recreational disturbance, and to demonstrate that policies are sustainable.
Object
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: 21834
Received: 16/03/2020
Respondent: Natural England
Natural England objects to the current wording of Policy 3 and considers that the policy and supporting text are inadequate to protect, maintain, restore and enhance the natural environmental assets of the area and the benefits arising from these for residents, workers and visitors. It will not ensure the delivery of GI of sufficient quality and quantity in the right locations, nor help the Plan to meet the sustainability criteria or adapt to climate change. It contains too much uncertainty and needs to explain the hierarchies of site protection and mitigation.
The natural environmental assets found in the Greater Norwich area, and adjoining it, provide immense benefits that deliver across all three pillars of sustainability. In terms of benefits to the economy and society alone, these would run into tens of millions of pounds if they were calculated over the lifetime of the Plan.
We strongly recommend that Policy 3 and the supporting text are substantially amended and expanded. The 175 words assigned to the current natural environment section of Policy 3 cannot do justice to what is required for the Greater Norwich area and surroundings. Much of the wording and maps in Policy 1: Addressing climate change and protecting environmental assets in the current Joint Core Strategy (2011) remains valid and relevant. Parts of it could form the basis of a new Policy 3, which needs to cover measures in relation to climate change adaptation, halting and reversing the loss of biodiversity in relation to the Government’s 25 year Environment Plan and Nature Recovery Networks, biodiversity net gain, recreational disturbance, suitable alternative greenspace (SANGS) and GI networks.
We also suggest 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).
GI references in the Plan repeatedly refer to the strategic GI network as set out on the (basic) Map 8 and very little else. The Local Plan needs to provide a strategic document that sets out what the GI network will look like on the ground, how and where it will be delivered and the timescale, together with detailed information about the existing GI network and how it, too, will be protected, enhanced or expand. At this stage of the plan process there needs to be far more detail provided to be certain that it will be delivered, and for the HRA to be able to assess in relation to the mitigation measures that have been identified.
Natural England, together with other partners, would very much like to work with the local authorities in revising and expanding Policy 3 to ensure it is comprehensive and robust.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
We support Broadland District, Norwich City and South Norfolk Councils’ preparation of a joint Local Plan to ensure a consistent approach to planning across the Greater Norwich area, with policies aligned with the revised National Planning Policy Framework (NPPF).
We have made detailed comments in this letter in relation to the following Greater Norwich Local Plan (GNLP) consultation documents:
Draft Local Plan – Part 1 The Strategy
Draft Sites Document
Habitats Regulations Assessment of GNLP, December 2019
Sustainability Appraisal and Strategic Environmental Assessment, January 2020
Natural England acknowledges that the findings of supporting documents including the draft Greater Norwich Water Cycle Study (WCS) (AECOM 2019) and the emerging Green Infrastructure and Recreational Impact Avoidance and Mitigation Strategy (GIRAMS) will need to be incorporated in the policies of the Local Plan and supporting documents, once these are finalised.
To summarise our response briefly, we broadly welcome the progress and development of aspects of the Local Plan and supporting documents to date, though Natural England is not yet satisfied that the relevant Plan polices will provide sufficient mitigation to ensure that there will be no adverse impacts to designated sites alone, and in-combination, through changes in water quality and resources and in regard to recreational disturbance, and to demonstrate that policies are sustainable.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Question 24: Do you support, object or have any comments relating to the approach to other strategic infrastructure (energy, water, health care, schools and green infrastructure)?
Representation ID: 21835
Received: 16/03/2020
Respondent: Natural England
There are no specific references to GI in the supporting text or policy and we advise that this needs to change with due recognition and importance given. GI is essential for the delivery of sustainable development. Strategic infrastructure has been identified to meet economic and social imperatives but fails to identify any strategic infrastructure to meet environmental requirements. In the absence of the identification of strategic GI it is unclear how the Plan will deliver sustainable growth, or address the impacts of climate change. This needs to be addressed under the heading of ‘Strategic Green Infrastructure’ both in the supporting text and within the policy wording.
The findings of the WSC may need to be reflected in the policy and supporting text.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
We support Broadland District, Norwich City and South Norfolk Councils’ preparation of a joint Local Plan to ensure a consistent approach to planning across the Greater Norwich area, with policies aligned with the revised National Planning Policy Framework (NPPF).
We have made detailed comments in this letter in relation to the following Greater Norwich Local Plan (GNLP) consultation documents:
Draft Local Plan – Part 1 The Strategy
Draft Sites Document
Habitats Regulations Assessment of GNLP, December 2019
Sustainability Appraisal and Strategic Environmental Assessment, January 2020
Natural England acknowledges that the findings of supporting documents including the draft Greater Norwich Water Cycle Study (WCS) (AECOM 2019) and the emerging Green Infrastructure and Recreational Impact Avoidance and Mitigation Strategy (GIRAMS) will need to be incorporated in the policies of the Local Plan and supporting documents, once these are finalised.
To summarise our response briefly, we broadly welcome the progress and development of aspects of the Local Plan and supporting documents to date, though Natural England is not yet satisfied that the relevant Plan polices will provide sufficient mitigation to ensure that there will be no adverse impacts to designated sites alone, and in-combination, through changes in water quality and resources and in regard to recreational disturbance, and to demonstrate that policies are sustainable.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Question 35: Do you support, object or have any comments relating to the approach to tourism, leisure, environmental and cultural industries?
Representation ID: 21836
Received: 16/03/2020
Respondent: Natural England
It would be helpful to recognise the benefits and contributions that multi-functional GI delivers to making places more attractive to employers & employees in the greater Norwich area, as well as the contributions that the county’s natural environmental assets make to the Norfolk economy. It can be used to enhance the environment in the economic centres of settlements and help attract inward investment.
Under 5.in the policy, second bullet point, we suggest the wording should be amended to include the protection, enhancement and expansion of the GI network, rather than simply its implementation.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
We support Broadland District, Norwich City and South Norfolk Councils’ preparation of a joint Local Plan to ensure a consistent approach to planning across the Greater Norwich area, with policies aligned with the revised National Planning Policy Framework (NPPF).
We have made detailed comments in this letter in relation to the following Greater Norwich Local Plan (GNLP) consultation documents:
Draft Local Plan – Part 1 The Strategy
Draft Sites Document
Habitats Regulations Assessment of GNLP, December 2019
Sustainability Appraisal and Strategic Environmental Assessment, January 2020
Natural England acknowledges that the findings of supporting documents including the draft Greater Norwich Water Cycle Study (WCS) (AECOM 2019) and the emerging Green Infrastructure and Recreational Impact Avoidance and Mitigation Strategy (GIRAMS) will need to be incorporated in the policies of the Local Plan and supporting documents, once these are finalised.
To summarise our response briefly, we broadly welcome the progress and development of aspects of the Local Plan and supporting documents to date, though Natural England is not yet satisfied that the relevant Plan polices will provide sufficient mitigation to ensure that there will be no adverse impacts to designated sites alone, and in-combination, through changes in water quality and resources and in regard to recreational disturbance, and to demonstrate that policies are sustainable.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Question 48. Do you support or object or wish to comment any other aspect of the draft plan not covered in other questions? This includes the appendices below. Please identify particular issues.
Representation ID: 21837
Received: 16/03/2020
Respondent: Natural England
Natural England has not commented on the individual preferred sites for new allocation nor on the reasonable alternative sites identified, due to the number of sites involved and limitations on our resources.
We previously responded to a consultation on new, revised and small sites (our letter dated 14 December 2018; our ref: 262820). Our advice made in that response remains relevant to this current consultation on the selection and allocation of sites under the GNLP, and needs to be considered fully.
Similarly, the advice provided in this letter regarding various Plan policies and the HRA needs to be incorporated into the policy and supporting text of each relevant individual site allocation policy, making it clear that the allocation will only be deliverable if a project level HRA can demonstrate no adverse effects. Any mitigation measures identified through the HRA or the emerging GIRAMS need to be included too.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
We support Broadland District, Norwich City and South Norfolk Councils’ preparation of a joint Local Plan to ensure a consistent approach to planning across the Greater Norwich area, with policies aligned with the revised National Planning Policy Framework (NPPF).
We have made detailed comments in this letter in relation to the following Greater Norwich Local Plan (GNLP) consultation documents:
Draft Local Plan – Part 1 The Strategy
Draft Sites Document
Habitats Regulations Assessment of GNLP, December 2019
Sustainability Appraisal and Strategic Environmental Assessment, January 2020
Natural England acknowledges that the findings of supporting documents including the draft Greater Norwich Water Cycle Study (WCS) (AECOM 2019) and the emerging Green Infrastructure and Recreational Impact Avoidance and Mitigation Strategy (GIRAMS) will need to be incorporated in the policies of the Local Plan and supporting documents, once these are finalised.
To summarise our response briefly, we broadly welcome the progress and development of aspects of the Local Plan and supporting documents to date, though Natural England is not yet satisfied that the relevant Plan polices will provide sufficient mitigation to ensure that there will be no adverse impacts to designated sites alone, and in-combination, through changes in water quality and resources and in regard to recreational disturbance, and to demonstrate that policies are sustainable.
Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Question 19: Do you support, object or have any comments relating to the specific requirements of the policy?
Representation ID: 23149
Received: 16/03/2020
Respondent: Natural England
We warmly welcome and support this policy.
Under (3) we consider the provision of accessible GI for recreational uses should be included within the policy. This is necessary to help mitigate the impacts of additional recreational pressure from new housing development on designated sites.
Under (9) we endorse the adoption of the higher standard for water efficiency under the Building Regulations, which is also supported by evidence in the WCS. Reference to retrofitting existing buildings with water efficiency measures has also been as identified as essential in the WCS in terms of managing water demand. We suggest it would be appropriate to include some wording in this policy which recognises this need, and supports its implementation should Government adopt this approach in future.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
We support Broadland District, Norwich City and South Norfolk Councils’ preparation of a joint Local Plan to ensure a consistent approach to planning across the Greater Norwich area, with policies aligned with the revised National Planning Policy Framework (NPPF).
We have made detailed comments in this letter in relation to the following Greater Norwich Local Plan (GNLP) consultation documents:
Draft Local Plan – Part 1 The Strategy
Draft Sites Document
Habitats Regulations Assessment of GNLP, December 2019
Sustainability Appraisal and Strategic Environmental Assessment, January 2020
Natural England acknowledges that the findings of supporting documents including the draft Greater Norwich Water Cycle Study (WCS) (AECOM 2019) and the emerging Green Infrastructure and Recreational Impact Avoidance and Mitigation Strategy (GIRAMS) will need to be incorporated in the policies of the Local Plan and supporting documents, once these are finalised.
To summarise our response briefly, we broadly welcome the progress and development of aspects of the Local Plan and supporting documents to date, though Natural England is not yet satisfied that the relevant Plan polices will provide sufficient mitigation to ensure that there will be no adverse impacts to designated sites alone, and in-combination, through changes in water quality and resources and in regard to recreational disturbance, and to demonstrate that policies are sustainable.
