GNLP 2045 Regulation 20 Scoping Consultation

Thank you for your consultation on the above dated 17 August 2026 which was received by Natural England on the same date.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
We welcome the opportunity to offer our advice at this early stage of the Local Plan process. We would be happy to discuss any of the ideas within this letter further.
Natural England notes that your Local Plan is progressing ahead of the relevant Spatial Development Strategy (SDS) and our current advice reflect this. We would also encourage your Authority to consider the implications of other plans or strategies which may be relevant to your
area, including those covering national or regional priorities for development and infrastructure.

The Importance of Nature
Natural England’s Strategy recognises that nature plays a vital role as the foundation of economic growth, and its degradation, both globally and locally, can disrupt food, water, health and supply chains. Therefore, any threats to the natural environment also threaten other systems vital to our communities. Climate change is a profound threat to nature and people.
As the government’s adviser on the natural environment, climate change is central to Natural England’s work. The natural environment is experiencing the impacts of climate change and needs to recover, adapt to change and build resilience. When delivering the homes, jobs and infrastructure that we need for economic growth, we must collectively ensure that we embed nature into the heart
of development from the outset to safeguard those ecosystems that underpin our collective security
and prosperity. Sustainable development can and should contribute to net zero through supporting nature recovery and climate change mitigation and adaptation, helping both nature and people adapt, through Nature-based Solutions (NbS).
We advise that, in line with the National Planning Policy Framework (NPPF) (August 2026), local plans should provide for new development, and improvement of the environment, in a way which promotes a sustainable pattern of growth and seeks to mitigate climate change and adapt to its effects (S1).
In addition, of the three local authorities which make up the Greater Norwich Local Plan area, Norwich City Council and Broadland District Council have each declared a climate emergency, and produced an accompanying programme or plan of actions to help address this. We advise that, along with the Norfolk Local Nature Recovery Strategy (LNRS), these are considered at every stage
of the Plan making process to ensure biodiversity and nature is protected and enhanced by policies.
The Plan should also define health inequalities and highlight how equitable access to green and
blue space can reduce health inequalities. The World Health Organization (WHO) definition of health inequalities (or inequities) can be used which defines them as unfair, systematic, and avoidable differences in health status, life expectancy, and access to care between population
groups. You may find the following reports useful in helping with this: Improving access to greenspace: 2020 review (Chapter 3) and Public Health England - Healthy Places - GOV.UK.
By supporting nature recovery and climate change mitigation and adaptation, other challenges, such as flooding, mental and physical well-being and maintaining a healthy economy, will also be addressed.

The Plan Vision
Natural England advises that the Plan’s vision and development strategy should address impacts on, and opportunities for, the natural environment and set out the ambition to improve the environment with specific reference to issues of local importance. The Plan should take a strategic approach to secure positive outcomes both for growth and the protection and enhancement of the natural environment, and include this within the vision’s measurable outcomes. This includes providing a net gain for biodiversity, delivering green infrastructure, and considering opportunities to enhance and improve connectivity for nature and for people.
The priorities for the vision should include how the plan will protect and enhance the natural geodiverse and historic environment and plan for climate change mitigation and adaptation, with specific reference to the local area. This should include:
• utilising the Norfolk Local Nature Recovery Strategy to direct the potential areas for enhancement and align the local priorities for nature
• considering opportunities to enhance and improve habitat connectivity and providing net environmental gains for the environment
• improve access to nature as part of delivering health and wellbeing, including implementing green and blue infrastructure standards.
• conserving and enhancing the natural beauty of Protected Landscapes adjacent to the Plan area.
The vision should reflect other plans and strategies as appropriate such as the Biodiversity Action
Plan, Norfolk Local Nature Recovery Strategy (LNRS), the Greater Norwich Green Infrastructure Strategy (April 2025), Norfolk County Council Local Transport Plan, the Greater Norwich Local Cycling and Walking Infrastructure Plan, the Broads Management Plan, and water resource
management plans.
Regarding the Strengths, Weaknesses, Opportunities and Threats (SWOT) analysis, in the
‘Opportunites’ column we recommend adding the Greater Norwich Green Infrastructure Strategy and the Norfolk LNRS. These strategies are opportunities to deliver, safeguard and increase biodiversity and green infrastructure, which underpin and support many of the strengths listed, and can be used to address some of the issues listed under ‘Weaknesses’. See below for further details about the benefits of good green infrastructure further on in our response.
Natural England advises that the nutrient pollution of Norfolk’s internationally important rivers and
broads, which support nature, people and the local economies, is a significant threat, rather than
nutrient neutrality itself. Nutrient neutrality is a strategic mitigation measure to address this pollution
issue, which occurs throughout much of the Local Plan area.
Recreational disturbance, arising from both existing and planned growth, is a threat to many important designated wildlife sites, which are valued by residents and visitors alike, and which make a significant contribution to Norfolk’s economy. We suggest that recreational disturbance is added to the list of threats.
Similarly, biodiversity loss, which threatens the Plan area’s rich environmental assets, and its agricultural, food and tourism sectors should also be added.
Green Infrastructure
Well-designed green (and blue) infrastructure (GI) are essential and critical assets which can deliver
multiple functions including:
• improving people’s mental and physical health
• supporting local community and social engagement
• enhancing nature and biodiversity
• encouraging active travel
• cooling urban areas during heat waves
• attracting financial investment by increasing the attractiveness of local areas
• reducing water run-off during flash flooding
• storing carbon
• providing sustainable drainage
• contribute to place-making

Specific Local Plan Issues
The table below sets out Natural England's advice on specific Local Plan issues. More detailed
advice on these, and other Local Plan issues, can be found in Annex A and Annex B.

Table 1: Natural England's advice on specific Local Plan issues - see attachment


Evidence for the Local Plan
The table below sets out evidence that Natural England would expect to see underpinning policy
decisions, with further advice provided in Annex A where relevant.

Table 2: Evidence required to underpin policy decisions in the Local Plan - see attachement

Other Advice
We welcome the opportunity to comment on the Local Plan at this early stage. We are interested in engaging further with the Local Plan process through workshops, meetings and other consultations.

Thank you for your consultation on the above dated 17 August 2026 which was received by Natural England on the same date.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
We welcome the opportunity to offer our advice at this early stage of the Local Plan process. We would be happy to discuss any of the ideas within this letter further.
Natural England notes that your Local Plan is progressing ahead of the relevant Spatial Development Strategy (SDS) and our current advice reflect this. We would also encourage your Authority to consider the implications of other plans or strategies which may be relevant to your
area, including those covering national or regional priorities for development and infrastructure.

The Importance of Nature
Natural England’s Strategy recognises that nature plays a vital role as the foundation of economic growth, and its degradation, both globally and locally, can disrupt food, water, health and supply chains. Therefore, any threats to the natural environment also threaten other systems vital to our communities. Climate change is a profound threat to nature and people.
As the government’s adviser on the natural environment, climate change is central to Natural England’s work. The natural environment is experiencing the impacts of climate change and needs to recover, adapt to change and build resilience. When delivering the homes, jobs and infrastructure that we need for economic growth, we must collectively ensure that we embed nature into the heart
of development from the outset to safeguard those ecosystems that underpin our collective security
and prosperity. Sustainable development can and should contribute to net zero through supporting nature recovery and climate change mitigation and adaptation, helping both nature and people adapt, through Nature-based Solutions (NbS).
We advise that, in line with the National Planning Policy Framework (NPPF) (August 2026), local plans should provide for new development, and improvement of the environment, in a way which promotes a sustainable pattern of growth and seeks to mitigate climate change and adapt to its effects (S1).
In addition, of the three local authorities which make up the Greater Norwich Local Plan area, Norwich City Council and Broadland District Council have each declared a climate emergency, and produced an accompanying programme or plan of actions to help address this. We advise that, along with the Norfolk Local Nature Recovery Strategy (LNRS), these are considered at every stage
of the Plan making process to ensure biodiversity and nature is protected and enhanced by policies.
The Plan should also define health inequalities and highlight how equitable access to green and
blue space can reduce health inequalities. The World Health Organization (WHO) definition of health inequalities (or inequities) can be used which defines them as unfair, systematic, and avoidable differences in health status, life expectancy, and access to care between population
groups. You may find the following reports useful in helping with this: Improving access to greenspace: 2020 review (Chapter 3) and Public Health England - Healthy Places - GOV.UK.
By supporting nature recovery and climate change mitigation and adaptation, other challenges, such as flooding, mental and physical well-being and maintaining a healthy economy, will also be addressed.

The Plan Vision
Natural England advises that the Plan’s vision and development strategy should address impacts on, and opportunities for, the natural environment and set out the ambition to improve the environment with specific reference to issues of local importance. The Plan should take a strategic approach to secure positive outcomes both for growth and the protection and enhancement of the natural environment, and include this within the vision’s measurable outcomes. This includes providing a net gain for biodiversity, delivering green infrastructure, and considering opportunities to enhance and improve connectivity for nature and for people.
The priorities for the vision should include how the plan will protect and enhance the natural geodiverse and historic environment and plan for climate change mitigation and adaptation, with specific reference to the local area. This should include:
• utilising the Norfolk Local Nature Recovery Strategy to direct the potential areas for enhancement and align the local priorities for nature
• considering opportunities to enhance and improve habitat connectivity and providing net environmental gains for the environment
• improve access to nature as part of delivering health and wellbeing, including implementing green and blue infrastructure standards.
• conserving and enhancing the natural beauty of Protected Landscapes adjacent to the Plan area.
The vision should reflect other plans and strategies as appropriate such as the Biodiversity Action
Plan, Norfolk Local Nature Recovery Strategy (LNRS), the Greater Norwich Green Infrastructure Strategy (April 2025), Norfolk County Council Local Transport Plan, the Greater Norwich Local Cycling and Walking Infrastructure Plan, the Broads Management Plan, and water resource
management plans.
Regarding the Strengths, Weaknesses, Opportunities and Threats (SWOT) analysis, in the
‘Opportunites’ column we recommend adding the Greater Norwich Green Infrastructure Strategy and the Norfolk LNRS. These strategies are opportunities to deliver, safeguard and increase biodiversity and green infrastructure, which underpin and support many of the strengths listed, and can be used to address some of the issues listed under ‘Weaknesses’. See below for further details about the benefits of good green infrastructure further on in our response.
Natural England advises that the nutrient pollution of Norfolk’s internationally important rivers and
broads, which support nature, people and the local economies, is a significant threat, rather than
nutrient neutrality itself. Nutrient neutrality is a strategic mitigation measure to address this pollution
issue, which occurs throughout much of the Local Plan area.
Recreational disturbance, arising from both existing and planned growth, is a threat to many important designated wildlife sites, which are valued by residents and visitors alike, and which make a significant contribution to Norfolk’s economy. We suggest that recreational disturbance is added to the list of threats.
Similarly, biodiversity loss, which threatens the Plan area’s rich environmental assets, and its agricultural, food and tourism sectors should also be added.
Green Infrastructure
Well-designed green (and blue) infrastructure (GI) are essential and critical assets which can deliver
multiple functions including:
• improving people’s mental and physical health
• supporting local community and social engagement
• enhancing nature and biodiversity
• encouraging active travel
• cooling urban areas during heat waves
• attracting financial investment by increasing the attractiveness of local areas
• reducing water run-off during flash flooding
• storing carbon
• providing sustainable drainage
• contribute to place-making

Specific Local Plan Issues
The table below sets out Natural England's advice on specific Local Plan issues. More detailed
advice on these, and other Local Plan issues, can be found in Annex A and Annex B.

Table 1: Natural England's advice on specific Local Plan issues - see attachment


Evidence for the Local Plan
The table below sets out evidence that Natural England would expect to see underpinning policy
decisions, with further advice provided in Annex A where relevant.

Table 2: Evidence required to underpin policy decisions in the Local Plan - see attachement

Other Advice
We welcome the opportunity to comment on the Local Plan at this early stage. We are interested in engaging further with the Local Plan process through workshops, meetings and other consultations.

Thank you for your consultation on the above dated 17 August 2026 which was received by Natural England on the same date.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
We welcome the opportunity to offer our advice at this early stage of the Local Plan process. We would be happy to discuss any of the ideas within this letter further.
Natural England notes that your Local Plan is progressing ahead of the relevant Spatial Development Strategy (SDS) and our current advice reflect this. We would also encourage your Authority to consider the implications of other plans or strategies which may be relevant to your
area, including those covering national or regional priorities for development and infrastructure.

The Importance of Nature
Natural England’s Strategy recognises that nature plays a vital role as the foundation of economic growth, and its degradation, both globally and locally, can disrupt food, water, health and supply chains. Therefore, any threats to the natural environment also threaten other systems vital to our communities. Climate change is a profound threat to nature and people.
As the government’s adviser on the natural environment, climate change is central to Natural England’s work. The natural environment is experiencing the impacts of climate change and needs to recover, adapt to change and build resilience. When delivering the homes, jobs and infrastructure that we need for economic growth, we must collectively ensure that we embed nature into the heart
of development from the outset to safeguard those ecosystems that underpin our collective security
and prosperity. Sustainable development can and should contribute to net zero through supporting nature recovery and climate change mitigation and adaptation, helping both nature and people adapt, through Nature-based Solutions (NbS).
We advise that, in line with the National Planning Policy Framework (NPPF) (August 2026), local plans should provide for new development, and improvement of the environment, in a way which promotes a sustainable pattern of growth and seeks to mitigate climate change and adapt to its effects (S1).
In addition, of the three local authorities which make up the Greater Norwich Local Plan area, Norwich City Council and Broadland District Council have each declared a climate emergency, and produced an accompanying programme or plan of actions to help address this. We advise that, along with the Norfolk Local Nature Recovery Strategy (LNRS), these are considered at every stage
of the Plan making process to ensure biodiversity and nature is protected and enhanced by policies.
The Plan should also define health inequalities and highlight how equitable access to green and
blue space can reduce health inequalities. The World Health Organization (WHO) definition of health inequalities (or inequities) can be used which defines them as unfair, systematic, and avoidable differences in health status, life expectancy, and access to care between population
groups. You may find the following reports useful in helping with this: Improving access to greenspace: 2020 review (Chapter 3) and Public Health England - Healthy Places - GOV.UK.
By supporting nature recovery and climate change mitigation and adaptation, other challenges, such as flooding, mental and physical well-being and maintaining a healthy economy, will also be addressed.

The Plan Vision
Natural England advises that the Plan’s vision and development strategy should address impacts on, and opportunities for, the natural environment and set out the ambition to improve the environment with specific reference to issues of local importance. The Plan should take a strategic approach to secure positive outcomes both for growth and the protection and enhancement of the natural environment, and include this within the vision’s measurable outcomes. This includes providing a net gain for biodiversity, delivering green infrastructure, and considering opportunities to enhance and improve connectivity for nature and for people.
The priorities for the vision should include how the plan will protect and enhance the natural geodiverse and historic environment and plan for climate change mitigation and adaptation, with specific reference to the local area. This should include:
• utilising the Norfolk Local Nature Recovery Strategy to direct the potential areas for enhancement and align the local priorities for nature
• considering opportunities to enhance and improve habitat connectivity and providing net environmental gains for the environment
• improve access to nature as part of delivering health and wellbeing, including implementing green and blue infrastructure standards.
• conserving and enhancing the natural beauty of Protected Landscapes adjacent to the Plan area.
The vision should reflect other plans and strategies as appropriate such as the Biodiversity Action
Plan, Norfolk Local Nature Recovery Strategy (LNRS), the Greater Norwich Green Infrastructure Strategy (April 2025), Norfolk County Council Local Transport Plan, the Greater Norwich Local Cycling and Walking Infrastructure Plan, the Broads Management Plan, and water resource
management plans.
Regarding the Strengths, Weaknesses, Opportunities and Threats (SWOT) analysis, in the
‘Opportunites’ column we recommend adding the Greater Norwich Green Infrastructure Strategy and the Norfolk LNRS. These strategies are opportunities to deliver, safeguard and increase biodiversity and green infrastructure, which underpin and support many of the strengths listed, and can be used to address some of the issues listed under ‘Weaknesses’. See below for further details about the benefits of good green infrastructure further on in our response.
Natural England advises that the nutrient pollution of Norfolk’s internationally important rivers and
broads, which support nature, people and the local economies, is a significant threat, rather than
nutrient neutrality itself. Nutrient neutrality is a strategic mitigation measure to address this pollution
issue, which occurs throughout much of the Local Plan area.
Recreational disturbance, arising from both existing and planned growth, is a threat to many important designated wildlife sites, which are valued by residents and visitors alike, and which make a significant contribution to Norfolk’s economy. We suggest that recreational disturbance is added to the list of threats.
Similarly, biodiversity loss, which threatens the Plan area’s rich environmental assets, and its agricultural, food and tourism sectors should also be added.
Green Infrastructure
Well-designed green (and blue) infrastructure (GI) are essential and critical assets which can deliver
multiple functions including:
• improving people’s mental and physical health
• supporting local community and social engagement
• enhancing nature and biodiversity
• encouraging active travel
• cooling urban areas during heat waves
• attracting financial investment by increasing the attractiveness of local areas
• reducing water run-off during flash flooding
• storing carbon
• providing sustainable drainage
• contribute to place-making

Specific Local Plan Issues
The table below sets out Natural England's advice on specific Local Plan issues. More detailed
advice on these, and other Local Plan issues, can be found in Annex A and Annex B.

Table 1: Natural England's advice on specific Local Plan issues - see attachment


Evidence for the Local Plan
The table below sets out evidence that Natural England would expect to see underpinning policy
decisions, with further advice provided in Annex A where relevant.

Table 2: Evidence required to underpin policy decisions in the Local Plan - see attachement

Other Advice
We welcome the opportunity to comment on the Local Plan at this early stage. We are interested in engaging further with the Local Plan process through workshops, meetings and other consultations.