GNLP 2045 Regulation 20 Scoping Consultation

I would have expected reference to biodiversity in the threats section.

SWOT Analysis fails to include the fact they have a National Park, and potential landscape opportunities for carbon offsetting, flood management, BNG schemes etc on their hinterland. Also a powerful economic asset in its own right, and ensuring access is built into development will have a major benefit to residents lives.

Para 27 – whilst the Broads are not in your planning area, you still have a duty to further the purposes. And you need to ensure that schemes near to the Broads do not affect its special qualities.

Section 2.3, site allocations – please ensure you engage with the Broads Authority as early as possible if you are considering sites near to our boundary.

For question 14 around tourism, I’d like to see a strong commitment to safeguarding land needed to implementing the LCWIP, and also focusing development around it when it comes to the Broads. Both for avoiding the tourism congestion peaks within the Broads, but boosting access for the large number of people without a car in the city.

This was published prior to the new NPPF, so you can set energy efficiency standards. We would be interested in how you plan to do this, if indeed you do.

There is no mention of the Shared Standards from Anglian Water et al that seeks water usage better than 110 l/h/d. And the new NPPF supports this stricter water efficiency standard if there is evidence. The Local Plan for the Broads seeks 90l/h/d.

Will you set BNG of more than 10% on certain sites?

You do not mention the Broads in this section. You have a duty to further the purposes of the Broads Authority. What happens near the Broads, but outside, can affect the Broads. The new NPPF refers to the special qualities of the Broads. You need to ensure you talk about the Broads and its setting.

Recreational Open Space, Sports and Allotments Needs Assessment – this needs to cover the entire Broadland, Norwich and South Norfolk area, including the Broads. You will be aware that we have regard to/defer to the open space standards of our districts.

As you assess sites, please ensure you consult us early on on any sites near to our border.

Depending on where they are, the main issues relating to sites near our border will be dark skies impact, the quality of water run off into the Broads, landscape impact.

You will recall no doubt that we defer to/have regard to the policies and standards of our districts when it comes to affordable housing, open space and play and retail.

On water and infrastructure, the focus just seems to be on the potable water supply. A big factor across the area in the next few years will be agricultural reservoirs due to the climate change driven constraints on summer water abstraction, and potentially even on winter abstraction with Hands Off Flow rates being hit more frequently. This also helps protect the aforementioned landscape.

Non-Settlement Maps - Local Plan for the Broads - Publication version (this was a hyperlink but does not copy over!) pages 50 and 52 show trackways that we safeguard in our current local plan and intend to do the same in our emerging one. We ask that you do the same for the length of the routes in your planning area. Great Yarmouth Borough Council have done the same for their area (page 51 of that document).

We support the Active Travel and public transport provision through infrastructure with a strong focus on walking, wheeling and cycling. Ensuring safe, comfortable and attractive routes for all users with easier access for people with mobility and sensory needs is paramount (Broads Plan, E1; IAS, 4.1, 4.7).

The Broads LCWIP has highlighted routes for inclusion as part of the leisure and tourism engagement alongside improvements to active travel provision in rural Broadland communities. This document should be included alongside the Norfolk LCWIP overarching plan. Add to 4. Evidence (Infrastructure topic paper).

Sports Facilities recognises open green spaces - is there scope to recognise access points for water-based recreation such as launch points, riverside walks, paddle trails and mooring links for enjoyment of blue spaces (IAS 6.1, 6.2, 6.3, 6.4, 6.5, 6.6).