Publication

Many of the protected sites have already been adversely affected as a result of nutrient loading from a variety of sources both diffuse and point. The challenge is to remove the adverse impact, not add to it.

Water quality is one of two factors influencing natural functioning of protected wetland sites. The other factor is water availability. Both of these factors if adverse can impact protected wetland sites both alone and in combination. Many protected sites and water bodies are in unfavourable condition as a result of decades of pollution combined with adjacent abstraction. These activities have already taken the ecology of these sites and their species far away from a natural state.

The plan needs to cover other land use categories, where soil is an important resource. For example peat soils are valuable in providing habitat for protected species and habitats, they also capture carbon and offset the impact of climate change. These peat soils also provide a growing medium for plants such as reed and sedge which are harvested. Often mismanagement of 'tilled soils' leads to an adverse impact on other soils types through sediment and nutrient loading. The range of soils types and their juxtaposition makes the overall landscape and the character types unique and special and makes the GNA what it is.

Soils within the landscape are important for practices other than agriculture. The suggestion from this section of the plan is that agriculture is the only activity where soil condition is relevant. This isn't the case.

The scale of abstraction to provide water for households and businesses is a key part of the puzzle and needs to be recognised in this part of the plan. It is the in-combination impact of a misuse of and a lack of respect for the water resource combined with natural climatic conditions that explains why the region is under severe drought stress.

The statement is inaccurate and biased suggesting agricultural activities are the cause of drought stress.

The plan delivers a bold statement describing enhanced quality of environmental assets but fails to qualify who will do this and how it will be funded. Most enhancement will be carried out by landowners, including conservation organisations using funding from charitable donations and various grants. Improved access to the countryside is desirable so long as it is and can be managed, and the effective use of developer contributions will be a key mechanism. RSPB very much doubts pressure on protected sites will be reduced by creating green infrastructure and the NW Woodland Country Park. c44,000 new homes with an average occupancy of c2 means on average 88,000 new residents. These residents will want to explore the GNA beyond the boundaries of green infrastructure on and linked to developments. This exploration needs to be mitigated for within the GIRAM process and appropriate allocation of develop contributions.

The paragraph states the quality of our environmental assets will be enhanced, but doesn't describe how or by whom. This quality will be maintained and enhanced by the landowners not the GNLP.

Important to stress that design features such as specific bricks providing a nest site for swifts are easy to incorporate and deliver and a simple example of net gain.

How this fund is managed and the monies allocated will be critical to providing both sustainable access and an enjoyable experience connecting people with nature. Many existing 'honey-pot' sites have infrastructure susceptible to more rapid deterioration e.g. trails constructed from natural materials. Upkeep and maintenance of safety standards are costly and will require support from this fund to enable the GNA to retain and sustain its attractiveness and appeal.

The maps are simplistic showing broad green lines with the assumption these proposals will be beneficial. Rather than providing a single colour showing access routes provide a more considered representation with a RAG rating approach which overlays the proposal describing limiting factors such as disturbance of wildlife or deterioration of infrastructure which will result from an increase in recreational activities.

The green infrastructure corridors suggest access will be promoted along routes which pass or lead to legally protected sites. Many of these sites harbour scarce species and congregations of species e.g. birds which are highly susceptible to alone or in-combination disturbance. Equally the corridors extend into neighbouring plan areas and it isn't clear whether this transitioning between these adjoining plan areas has been considered.

The GNA has already been recognised as being in a state of severe drought stress. Coupled with the impacts of climate change this will be one of the key limiting factors to the sustainable management of all interests within the plan area. Development, misuse and a lack of respect for the water resource has already caused damage to protected sites and lead to loss of protected species. Before considering the potential for further impact on these sites and species RSPB suggests redressing the balance towards more natural, historical conditions.

The information provided needs to be an honest appraisal of the situation and capture both the infrastructure and behavioural changes which will be needed to realise a sustainable approach. The reader is left with the impression that there are no barriers to development and the WCS is just another linked document with little to add. This is far from the truth. It also fails to show partnership with service/resource providers and a joint approach and suggests Anglian Water Services need to fix a problem not of their making. Only through partnership and collaboration will a sustainable, cooperative, future-proof end point be reached.

It is disappointing that such a core issue as water is reduced to a single line statement with a link to such a critical study. What this entry fails to state is that the WCS is only at the draft stage and open for consultation, having only been recently released. The information does not elaborate on some serious issues outlined within the WCS regarding headroom capacity of WRC, especially Whitlingham Trowse and therefore doesn't make it clear that until upgrades to these facilities are made development will not be permissible.