Publication

The NPPF 118(b) states that the plan should “recognise that some undeveloped land can perform many functions, such as for wildlife, recreation, flood risk mitigation, cooling/shading, carbon storage or food production;”. This paragraph doesn’t specifically state that the carbon balance of developments should be considered but 148 in the plan does say that the plan should “shape places in ways that contribute to radical reductions in greenhouse gas emissions...”.

We are pleased that this paragraph now mentions protecting Water Quality in SACs and habitats sites.

We are finding this paragraph sound but do raise the following comments. This new paragraph has removed mention of natural capital as far as we can see. The paragraph does not mention of natural functioning of ecosystems which would be beneficial.

In relation to green infrastructure, there is a Green Infrastructure Plan from 2007 online, but there is also a Green Infrastructure Study (Dec 2020). The latter maps out ‘core areas’ for grassland, woodland and wetland but there is no explanation what this means.

We are finding this paragraph sound but raise the following comments. We are pleased that our previous comments to paragraph 110 at the time have partially addressed this in new paragraph (115). However, it appears that the there is some confusion between green infrastructure and natural habitats. NPPF 171 keeps the two concepts separate “take a strategic approach to maintaining and enhancing networks of habitats and green infrastructure.” We would reiterate that green infrastructure is not necessarily biodiverse and may not include different habitats (e.g. farmland and playing fields).

Regarding paragraphs 120 to 122: While we are finding this paragraph sound we do have some concerns. We have gone in to more detail in this in our responses to policies 3 and 4.

The water section paragraph includes 3 paragraphs. 2 of these are about drinking water and only one (paragraph 122) with any mention of pollution. There is no information about WFD and risk to water quality.

It is disappointing none of our previous suggestions have been added here and, no links made to risk from development, or that preventing deterioration as part of WFD is not an 'aim' is a requirement.

The Local Plan must highlight WFD and links to water quality - it is statutory environmental legislation and should be referenced in the environment section. The "water" section (para 120-122) is sparse and there is required to acknowledge potential risks to the water environment from growth pressures. There is no mention of waste water issues and infrastructure.

Whilst we have not objected to this section, we do have some concerns. We have raised these formally in relation to policy 4 but are including the following advice here.

This section has not included anything here about rivers and water quality, such as: 'development will ensure that it is carried out in such locations and ways so that rivers and other water protected sites are protected from pollution and ensure water quality does not deteriorate'. Protecting the quality of the surrounding water environment and protected habitats should be a priority in the vision chapter.

It does not appear that our previous representation has been taken in to account. There is still no links to highlighting the importance for ensuring that water infrastructure (supply and foul) is delivered efficiently and in time to serve growth timescales in order to protect the water environment and prevent any breaches of environmental legislation. Paragraph 144 and 145 are still lacking in this commitment to provide sufficient levels of water infrastructure and ensure it is phased in-line with development timescales. We note that the plan states the commitment to “greater efficiency/green housing” but this does not remove the fact that growth will put pressure on existing infrastructure and the potential for serious impacts for the receiving water environment.

We are finding this policy sound but would raise the following comments on green infrastructure:

Green infrastructure is not always bio diverse and the plan has not mapped the habitats (just core areas in the GI study) or linked to the relevant partnerships (174). Green Infrastructure can vary in quality. For example, farming and playing fields would be of lower environmental quality than other forms. The plan should encourage multifunctional bio diverse green infrastructure links.

We would expect the policy to reference WFD as a starting point. It is important to reference water and water quality as this is something that designated sites rely on.

The policy should reference the Water Cycle Study and that development should be located in areas to avoid harm to the natural Environment.

Nothing has been added here in response to our comments referenced in our previous representation and as such they still stand. There is no mention of water quality at all and no acknowledgement of needing to protect it or risks from development. As previously stated, the policy does not reference WFD which is a key piece of legislation supporting and setting specific targets for enhancement and requires amending.

Paragraph 258 briefly references the Water Cycle Study (WCS). In our previous representation (to paragraph 228 at the time), given our detailed feedback it is disappointing to see that very little has been taken on board. The WCS will provide the basis/foundation for high level strategic decision with regards to foul wastewater infrastructure and growth, so the local Plan should really discuss the purpose of the WCS in more detail and make it clear why one has been undertaken. It currently does not do this.

The local plan would benefit in highlighting key findings/recommendations from the WCS. As a minimum this paragraph could highlight sites/areas where growth may be an issue in terms of wastewater infrastructure provisions or outline the purpose of the WCS and how it should be utilised by the local authority to strategically and sustainably place growth within the district.
We note that a paragraph has been added to the “appendices 1 infrastructure requirements” in the “water” section saying:

“The Water Cycle Study undertaken for the GNLP identified locations where there may be future capacity issues to be addressed for the growth proposed in the GNLP within the wastewater catchments of Aylsham, Foulsham, Long Stratton, Reepham, Rackheath, Diss, Ditchingham, Saxlingham, Whitlingham Trowse and Woodton. These issues should, at least in-part, be addressed by Anglian Water’s current Long Term Plan, but revisions may be necessary to this to fully address the GNLP proposals when finalised”.

This is the most detail on the WCS in the entire plan. This paragraph should not be hidden away in the appendices but should be given its own space in the main section of the Local Plan. As previously stated, the main body of the Local Plan needs to provide context to the WCS and clearly highlight any barrier/blockers to development identified.

Increasingly there should be a framework for the next local plan. WRC capacity has potential for major impact on growth.

Our comments outlined previously still apply and this could easily be incorporated into paragraph 258. Even better would be a separate foul water policy which would have been well received.

The climate change table (5) looks is a good improvement to the plan and we fully support this.