GNLP 2045 Regulation 20 Scoping Consultation

Additional Strengths
• Greater Norwich contains nationally and internationally important wildlife sites, including protected habitats, river valleys, wetlands, chalk rivers and ecological networks that provide significant biodiversity, climate adaptation and natural flood management benefits.
• A strong environmental sector, including conservation organisations, land managers and community groups, which can help deliver nature recovery and environmental enhancement.
• Significant opportunities for active travel and access to nature through the existing network of green infrastructure, public rights of way and open spaces.
Additional Weaknesses
• Ongoing habitat fragmentation across the wider landscape reduces ecological connectivity and the ability of species to adapt to climate change.
• Declining biodiversity and poor condition of some designated sites due to recreational pressure, pollution, water scarcity and land management pressures.
• Limited access to high-quality natural green space in some communities, contributing to inequalities in health and wellbeing.
• Continued dependence on private car travel in many locations, with associated impacts on carbon emissions, air quality and land use.
Additional Opportunities
• Delivery of the Local Nature Recovery Strategy, Greater Norwich Green Infrastructure Strategy and Biodiversity Net Gain requirements provides a major opportunity to create bigger, better and more connected habitats.
• Nature-based solutions such as wetland restoration, sustainable drainage systems, urban greening and woodland creation can address climate adaptation, flood risk, water quality and public health simultaneously.
• Strategic green infrastructure can support sustainable growth while improving access to nature and enhancing the attractiveness of places to live and work.
• Water-sensitive design and catchment-scale restoration could help address environmental constraints while improving resilience to drought and flooding.
Additional Threats
• Continued loss or deterioration of habitats and species through cumulative development impacts.
• Recreational pressure on protected sites resulting from planned housing growth if avoidance and mitigation measures are insufficient.
• Declining water quality and over-abstraction of water resources affecting rivers, wetlands and designated wildlife sites.
• Increased flood risk, overheating and other climate impacts on both communities and ecosystems.
• Failure to achieve nature recovery targets could undermine ecosystem services that support economic prosperity, health and climate resilience.
The current SWOT identifies environmental assets and climate change impacts, but it does not adequately recognise biodiversity loss, ecological connectivity, water quality, nature recovery or the role of natural capital in supporting sustainable growth. These issues are likely to become increasingly important over the plan period to 2040.

Yes. The evidence base should be expanded to include:
• Biodiversity trends, including species abundance, habitat extent and condition, and ecological network connectivity.
• Data from the Local Nature Recovery Strategy and Greater Norwich Green Infrastructure Strategy, including mapped opportunities for habitat creation and restoration.
• The condition status of Sites of Special Scientific Interest (SSSIs), County Wildlife Sites and other designated sites.
• Natural capital assessments that quantify the value of ecosystem services such as flood regulation, carbon storage, water purification, food production and health benefits.
• Water resource and water quality data, including abstraction pressures, catchment condition and ecological status of rivers and wetlands.
• Climate vulnerability mapping, including flood risk, surface water flooding, urban heat exposure and drought susceptibility.
• Accessible natural greenspace data and evidence of inequalities in access to nature, particularly for deprived communities.
• Public health evidence demonstrating links between access to green space, physical activity, mental health and wellbeing.
• Carbon sequestration and storage data for soils, peat, woodland and wetlands.
• Evidence on cumulative recreational impacts from housing growth on protected habitats and species.
• Green infrastructure audits identifying deficiencies and opportunities for strategic enhancement.
Including these datasets would help ensure that the plan considers not only housing and economic growth requirements, but also the environmental capacity of Greater Norwich and the long-term resilience of its communities and ecosystems. The consultation already recognises environmental assets, climate impacts and water constraints as important considerations so the additional evidence would provide a stronger basis for understanding these issues and developing measurable outcomes for the plan.

What has worked well
The principle of directing the majority of development towards the most sustainable locations remains sound. Concentrating growth close to jobs, education, healthcare, public transport and existing infrastructure can reduce the need to travel, support active travel and make more efficient use of resources.
What has not worked well
Over-reliance on greenfield development
Although a brownfield-first approach is supported, only around 22% of planned housing is on brownfield land. Greater efforts should be made to maximise previously developed land, particularly in Norwich and around public transport hubs, before releasing additional greenfield sites.
Housing delivery in environmentally constrained locations
Future growth needs to be more clearly aligned with environmental capacity, particularly regarding water resources, nutrient neutrality, biodiversity impacts and climate resilience. Growth should not be directed to locations where these issues cannot be adequately addressed.
Infrastructure often lags behind development
While improvements have been made, communities can experience pressure on water infrastructure and green infrastructure before upgrades are delivered. Future growth strategies should place stronger emphasis on infrastructure being provided early in the development process.
Limited emphasis on nature recovery
The existing strategy recognises environmental considerations but does not place sufficient emphasis on restoring nature at a landscape scale. New development should contribute towards delivering the Local Nature Recovery Strategy, the Greater Norwich Green Infrastructure Strategy, ecological connectivity and Biodiversity Net Gain beyond minimum requirements.
Car dependency in many growth locations
Some growth locations remain heavily dependent on private vehicles. Future development should prioritise locations where high-quality public transport, walking and cycling can be delivered from the outset.

Norfolk Wildlife Trust would support a growth strategy that places environmental capacity, climate resilience and sustainable development at its core.
Key priorities
1. Brownfield-first development
o Maximise redevelopment and intensification opportunities within Norwich and other urban centres.
o Prioritise sites close to rail stations, public transport corridors and existing services.
o Make best use of under-utilised urban land before releasing additional greenfield land.
2. Nature-positive growth
o Ensure development contributes to the recovery of wildlife and habitats.
o Protect designated sites and ecological networks.
o Deliver strategic green infrastructure and habitat creation alongside new development. Refer to the LNRS and Greater Norwich Green Infrastructure Strategy to guide this.
3. Climate-resilient communities
o Direct growth away from areas vulnerable to flooding and other climate risks.
o Require high standards of energy efficiency, sustainable drainage, urban greening and climate adaptation.
o Use nature-based solutions wherever possible.
4. Infrastructure-led development
o Growth should be aligned with water resources, wastewater capacity and green infrastructure.
o Development should only proceed where supporting infrastructure can be delivered in a timely manner.

• Continue to focus the majority of growth within the Norwich Urban Area and other sustainable settlements.
• Increase brownfield redevelopment and urban intensification where environmental quality can be maintained.
• Allow proportionate extensions to existing higher-order settlements where infrastructure and environmental capacity exist.
• Avoid excessive dispersal of development to smaller villages that are heavily car-dependent.

Key constraints that must shape the strategy
• Water supply and water resource limitations.
• Nutrient neutrality requirements.
• Protection of internationally, nationally and locally important wildlife sites and species.
• Climate change impacts, including flood risk and overheating.
• The need to recover biodiversity and meet national environmental targets.
Overall, the GNLP 2045 should seek to accommodate growth in locations that reduce carbon emissions, strengthen communities, enhance nature recovery and make efficient use of existing infrastructure, while ensuring that environmental constraints are treated as fundamental considerations rather than issues to be addressed later in the planning process.

Housing delivery should be improved through a combination of better site selection, infrastructure planning and place-making rather than by reducing environmental standards.
Key measures include:
• Prioritising development on sustainable, deliverable sites with realistic delivery trajectories and clear infrastructure requirements.
• Taking a genuinely brownfield-first approach. This can reduce pressure on valued countryside and biodiversity-rich land while making efficient use of existing infrastructure.
• Aligning development with infrastructure delivery from the outset, including water supply, wastewater treatment and green infrastructure.
• Providing greater certainty through clear design, climate and biodiversity requirements so that expectations are known early and delays are reduced.
Environmental safeguards such as Biodiversity Net Gain, climate adaptation measures and protection of designated sites should not be weakened in the pursuit of delivery. Instead, they should be integrated into plan-led site selection and infrastructure planning

Allocations should only be made where sites are environmentally suitable and capable of being served by sustainable transport and essential infrastructure. The objective should not simply be to maximise the number of small sites, but to achieve an appropriate balance between strategic sites, brownfield regeneration and smaller allocations

The plan should:
• Resist unnecessary isolated housing development that increases car dependence.
• Prioritise re-use of existing buildings over new build development in open countryside.
• Protect habitats, ecological networks and landscape character.
• Require biodiversity enhancement and nature recovery measures for rural developments.
• Avoid increasing recreational pressure on sensitive wildlife sites.
Overall, the GNLP 2045 should support rural communities while ensuring that development outside settlement boundaries remains genuinely sustainable, protects nature and contributes to climate resilience.

The plan should:
• Prioritise employment growth in accessible locations served by public transport, walking and cycling networks.
• Promote high environmental standards, low-carbon construction and climate-resilient business premises.
Economic growth should be consistent with environmental objectives. New employment development should contribute to:
• Net zero targets.
• Biodiversity recovery.
• Water efficiency.
• Sustainable transport objectives.
The rural economy should be supported through:
• Appropriate farm diversification.
• Nature-based enterprises.
• Sustainable tourism.
• Green skills and environmental land management businesses.
• Small-scale rural workspaces and business hubs.
The plan should recognise that nature recovery, regenerative farming, habitat restoration, carbon management and natural flood management can become increasingly important economic activities in rural areas.
To strengthen skills and workforce development the GNLP should promote green skills associated with clean energy, sustainable construction, habitat restoration and environmental management.
In terms of freight and logistics, the plan should:
• Encourage low-carbon freight solutions.
• Avoid locating logistics uses where they would create unacceptable impacts on communities, landscapes or sensitive habitats.

Tourism makes an important contribution to the Greater Norwich economy and should continue to be supported. However, future tourism growth should be consistent with environmental protection, nature recovery and climate resilience.
The GNLP should:
• Support sustainable tourism and eco-tourism initiatives.
• Encourage tourism linked to nature, heritage, culture and the landscape.
• Support appropriate visitor accommodation in sustainable locations.
• Promote active travel links between visitor destinations.
• Support investment in green infrastructure and access to nature.
Particular opportunities include developing tourism linked to:
• Wildlife and nature recovery.
• The Broads and river valleys.
• Walking, cycling and nature-based recreation.
• Local food and farming.
The plan should also recognise potential environmental pressures arising from tourism growth. New tourism development should avoid adverse impacts on protected habitats, sensitive landscapes and internationally important wildlife sites. Visitor management measures should be incorporated where necessary to ensure that increased recreation does not lead to habitat degradation or disturbance.
Overall, tourism should be viewed as an opportunity to support both economic prosperity and environmental enhancement, helping to reinforce Greater Norwich's reputation as a high-quality place to live, work and visit.