MM12 - Policy 6

We welcome the recognition given under (5) of Policy 6 to protect, enhance and expand the Green Infrastructure network.

Greater Norwich Local Plan: Main Modifications Consultation

Please find comments from Norfolk Wildlife Trust regarding the main modifications on the Greater Norwich Local Plan below.

Policy 1: The Sustainable Growth Strategy
We welcome the inclusion of the new paragraph 187 which recognises that at present, there is no need to pursue the development of a new settlement.

On map 7 it states there are 1,919 houses from windfall, whereas table 6 gives a windfall allowance of 830.
We ask for clarification on which windfall figure is correct, in order to ensure that there aren’t any outstanding errors in the collective/overall (sites & windfall) allocation numbers.

Policy 2: Sustainable Communities
Point 1: We support the inclusion of reference to non-car modes and the encouragement of walking, cycling and public transport in relation to ensuring access to developments.

Point 3: We support the inclusion of street trees and other tree planting.

Point 4: We support the inclusion of the following sentence: “In the most accessible locations in Norwich, regard should be given to providing low or car-free housing in accordance with Policy DM32 of the Norwich Development Management Policies Local Plan”, but recommend that in order to ensure delivery of this policy in planning decisions that a more objective goal is set in the policy requirements, such as ‘In the most accessible locations in Norwich, low or car-free housing should be delivered in accordance with Policy DM32 of the Norwich Development Management Policies Local Plan’.

Point 7: We support the inclusion of this new sentence.

Point 8: We support this inclusion of this new wording around flood risk and water efficiency.

Point 9: We are disappointed that the final sentence “If the potential to set more demanding standards locally is established by the Government, the highest potential standard will be applied in Greater Norwich” has been removed and recommend that this be re-inserted.

Point 10: We object to the revision of this paragraph. Promoting the use of established assessment frameworks can be a resource-efficient way of delivering better quality and higher standards in new developments. There is an urgent need to build genuinely net-zero buildings as soon as possible. A significant role therefore remains for local planning authorities in setting binding netzero policies that are more ambitious than the Building Regulations.

Policy 3: Environmental Protection and Enhancement
The Natural Environment - “Development proposals [will be required to conserve and (deleted text)] should (added text) enhance the natural environment” We recommend that this be changed to ‘Development proposals will be required to enhance the natural environment, through the following measures, where applicable’ in order to restore the certainty of delivery in the previous wording whilst reflecting the updated focus on nature’s restoration in current national policy.

We note that the wording in the paragraph about biodiversity net gain has been amended: “[It will need to (deleted text)] should (added text) be demonstrated”. We recommend that this be changed back to ‘It will need to be demonstrated’ in order to restore the certainty of delivery in the previous wording whilst reflecting the updated focus on nature’s restoration in current national policy.

We welcome the inclusion of the reference to provision or enhancement of green infrastructure.
We support the inclusion of the new paragraphs regarding the requirement for a Habitats Regulations Assessment on proposals that may adversely affect European sites and the statement that applications will be refused if it cannot be ascertained that there will be no adverse impact.

Policy 4 Strategic Infrastructure
Transport
We are disappointed to see the inclusion of reference in the GNLP for the proposed Norwich Western Link (NWL) development by Norfolk County Council as a regional connectivity project. At a previous consultation stage for the GNLP we received confirmation that the NWL is not necessary for the delivery of any of the allocations in the plan and recommend that the policy wording here is revised to make it clear that there is no direct policy support in the GNLP for this controversial proposal, which we understand is due to be submitted as a planning application in 2024.

Due to the national importance for bat conservation of the woodlands and surrounding landscape on the proposed NWL route (and compliance with the multiple wildlife laws protecting bat roosts from disturbance, damage and destruction), we do not consider that it is possible that the NWL can be delivered, and consider that the need and deliverability of the proposal should not be taken for granted and given any policy weight in the GNLP. We therefore strongly recommend that the wording of the regional connectivity section of this policy is revised to only reference elements which have demonstrated they are necessary for the delivery of the GNLP.

Policy 6 The Economy
Point 2: We note the new paragraph “Support for rural enterprises through the conversion of rural buildings, the development and diversification of agricultural and other land based rural businesses and well-designed new build. If new build development is proposed to meet local business and community needs in rural areas the use of previously developed land and sites that are physically well-related to existing settlements should be encouraged where suitable opportunities exist. For sites beyond existing settlements and in locations not well served by public transport then development should be well designed and sensitive to its surroundings, should not have an unacceptable impact on local roads and should exploit any opportunities to make the location more sustainable.” We recommend the addition of wording that any new development should not have an unacceptable impact on the environment.

Policy 7.1 The Norwich Urban Area including the fringe parishes
Point 5 The Built, Natural and Historic Environment: The wording of the final bullet point for this section has been weakened by changing the wording ‘assist in delivering’ to ‘have regard to’ the River Wensum Strategy. We recommend that the original wording be used.

East Norwich: We note that the new text removes mention of corridors and enhancing linkages, as well as removing the mention of local energy networks. We recommend that these be re-inserted.

Policy 7.6 New Settlements
We support the deletion of this policy for new settlements.

Sites
General comment: We support the change of wording in site specific policies to strengthen the protection of trees (eg Point 3 and paragraph 2.140). We recommend updated policy wording to be applied consistently across all other site allocation policies where applicable.

Norwich Policy GNLP0360/ 3053/R10 East Norwich Strategic Regeneration Area (ENSRA)
Point 13a: states that “Development must allow scope for greater use of the Rivers Wensum and Yare for water based recreation, leisure and tourism including the potential inclusion of marinas and riverside moorings”. We recommend that additional text is added to stipulate that this would not have an adverse impact on the nature conservation value of these rivers.

We support the addition of text outlining the need for new developments for all sites within ENSRA to include high-quality pedestrian and cycle routes.

Monitoring Framework

Table 3 Sustainability Appraisal Indicators
We suggest including “rates of active travel (walking and cycling)” as an indicator within the air theme, with a target to ‘increase’. This will demonstrate policy effectiveness of policy 2 ‘sustainable communities.

We recommend that the percentage loss of the ecological network indicator within the biodiversity, flora and fauna theme needs revision, as it has no metric to measure it by at present. We suggest that this monitoring target covers the extent of priority habitats (as measured on MAGIC mapping) as an interim metric. This can be revisited this once the Nature Recovery Network map is completed.

We recommend the inclusion of an indicator reflecting population number of protected species within the biodiversity, flora and fauna theme, with a target of increasing population sizes.