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Stage C Evidence Base
Sustainability Appraisal and Strategic Environmental Assessment (January 2020)
Representation ID: 20697
Received: 11/03/2020
Respondent: Norfolk Geodiversity Partnership
Box 2.3: SA Objective 3. Biodiversity, Geodiversity and Green Infrastructure
Geodiversity is mentioned in the title but is nowhere mentioned in the policy text. This means that the GNLP is unable to demonstrate that it is meeting sustainability measures for geological conservation, as per sections 109 and 1117 of the NPPF. This section needs rewriting to include County Geodiversity Sites and to explain how the GNLP can demonstrate that it can assess how it is meeting geoconservation objectives and what evidence base it will use.
Box 2.3: SA Objective 3. Biodiversity, Geodiversity and Green Infrastructure – Assessment Methodologies and Assumptions
* PAGE 27
Geodiversity is mentioned in the title but is nowhere mentioned in the policy text. This means that the GNLP is unable to demonstrate that it is meeting sustainability measures for geological conservation, as per sections 109 and 1117 of the NPPF. This section needs rewriting to explain how geoconservation objectives are to be assessed.
Para 1.
Mentions 'ecological receptors'. Are geodiversity assets considered to be one of these? If so that needs to be made explicit, and will need a lot of explanation !
List of Designated Sites
These include County Geodiversity Sites (CGS), which have equivalent Local Sites (non-statutory) status as County Wildlife Sites.
Para 3.
< Where a development proposal is coincident with, adjacent to or located in close proximity of an ecological receptor, it is assumed that negative effects associated with development will arise to some extent.>
How will negative effects of development proposals on geodiversity be assessed? What evidence base for sites will be used?
* PAGE 28
Para 1
<Negative impacts would be expected where the following ecological designations may be harmed or lost as a result of proposals>
The list should include County Geodiversity Sites (CGS).
Last para
< It is anticipated that the GNDP will require detailed ecological surveys and assessments to accompany future planning applications >
Geodiversity needs to be scoped as well as biodiversity.