Habitats Regulation Assessment (HRA)

Section 11.3.1 of the HRA sets out the outstanding matters needing resolution before the HRA could potentially conclude that the GNLP would not result in an adverse effect on the integrity of multiple European Sites. The Water Cycle Study and GIRAMS study should be completed in order to allow for the HRA to be updated, including allowing sufficient time for consultees and stakeholders to fully review their contents and offer comments.

The HRA is incomplete and makes recommendations for the further work necessary before a conclusion of no adverse effect can be made. Therefore at this stage there is insufficient evidence to demonstrate that adverse effects on European Sites can be avoided and therefore the GNLP does not comply with the Habitats Regulations.

Visitor Pressure -
Section 4.10.7 of the HRA refers to the measures set out in the GIRAMS report, but the GIRAMS report is still in draft form awaiting sign-off from its commissioning body, therefore its full recommendations cannot be incorporated into the GNLP policy text. Additionally, there is no certainty yet regarding the body which would collect and administer any developer contributions needed to fund the monitoring and mitigation actions necessary to demonstrate no adverse effect.

Water Quality -
Sections 4.10.15-4.10.19 of the HRA sets out likely multiple threats to European Sites from water pollution from new allocations reliant on WRCs at Reepham, Foulsham and Freethorpe, whilst section 10.2.3 notes uncertainties regarding the WRC at Whitlingham which serves the whole of Norwich.