GNLP 2045 Regulation 20 Scoping Consultation

Infrastructure should be planned and delivered through an infrastructure-led approach, rather than responding to development after permissions have been granted. The GNLP 2045 should ensure that housing and employment growth are aligned with the timely provision of transport, water, wastewater, green infrastructure and community facilities.
Key measures should include:
• Identifying infrastructure requirements alongside site allocations, with clear phasing and delivery triggers.
• Using a combination of developer contributions, Community Infrastructure Levy, public funding and partnership working to secure delivery.
• Giving greater priority to green infrastructure as essential infrastructure, rather than treating it as an optional enhancement. Refer to the Greater Norwich Green Infrastructure Strategy.
• Requiring major developments to deliver multifunctional green infrastructure that provides accessible greenspace, biodiversity gains, sustainable drainage, climate adaptation and health benefits.
The plan should also recognise that infrastructure must support not only growth, but also environmental resilience, particularly in relation to water resources, flood management and nature recovery. The evidence highlights significant water resource pressures and wastewater constraints, making coordinated infrastructure planning particularly important.

• Improved accessibility to housing, employment, services, sports and other community facilities?
The GNLP 2045 should promote a pattern of development that reduces the need to travel and enables people to access daily services sustainably. Access to green spaces and nature should be a key consideration.
The plan should:
• Support the "20-minute neighbourhood" principle where residents can access most everyday needs without relying on private cars.
• Prioritise walking, cycling and public transport infrastructure alongside development.
• Improve accessibility in rural areas through enhanced public transport, community transport and demand-responsive transport solutions.
• Ensure that new communities include accessible green spaces and community infrastructure from the outset.
• Improve connections between existing communities and key employment locations such as Norwich Research Park, Hethel and town centres.
Given continued inequalities in access to transport, services and green space across Greater Norwich, improving accessibility should remain a central objective of the growth strategy.

• Delivery of wastewater treatment capacity and address nutrient neutrality?
This should be treated as a fundamental constraint informing the growth strategy rather than an issue to address after sites have been allocated.
The GNLP 2045 should:
• Align the location and scale of growth with available wastewater treatment capacity.
• Be informed by the proposed Water Cycle Study and updated infrastructure evidence.
• Require early engagement with water companies and regulators during site allocation and master-planning.
• Prioritise water efficiency measures that reduce demand and wastewater generation.
• Mandate the use of sustainable drainage systems and water-sensitive urban design.
• Require strategic solutions for nutrient neutrality that deliver long-term environmental benefits.
• Promote nature-based solutions, including wetlands and habitat creation, that can contribute to nutrient mitigation while supporting biodiversity recovery.
The impacts of nutrient neutrality on the River Wensum Special Area of Conservation and the Broads Special Area of Conservation highlight the need for a strategic approach that protects internationally important habitats while enabling sustainable development.
All of the above should apply to water availability, not just wastewater treatment.
• Clean power and net zero objectives?
The GNLP 2045 should place climate mitigation and adaptation at the heart of the plan.
The plan should:
• Support renewable and low-carbon energy generation in appropriate locations.
• Mandate solar generation on buildings, brownfield land and previously developed sites where possible.
• Support heat networks where viable.
• Facilitate electricity grid upgrades required for decarbonisation and growth.
• Encourage electric vehicle charging infrastructure while ensuring priority is given to walking, cycling and public transport.
• Require developments to minimise operational carbon emissions.
• Require developments to incorporate green infrastructure that helps reduce overheating and increases climate resilience.
• Require energy-efficient design and delivery of the Future Homes Standard. New developments should be required to meet the highest energy efficiency standards.
The plan should also recognise that nature-based solutions are an essential component of achieving net zero. Habitat creation, woodland expansion, peat protection, wetland restoration and urban greening all contribute to carbon storage, climate adaptation and biodiversity recovery. Overall, the GNLP 2045 should integrate infrastructure planning, climate objectives and nature recovery into a single strategy that delivers sustainable growth while respecting environmental limits and improving quality of life for current and future residents.

• Set the most demanding local standards possible for water efficiency?
Yes. The GNLP 2045 should apply the highest local water efficiency standards that can be justified by the evidence. Greater Norwich lies within an area classified as experiencing serious water stress and contains internationally important wetland and river habitats that are vulnerable to abstraction pressures and climate change. The Broads, River Wensum, Norfolk Valley Fens are all highly sensitive to water resource pressures.
The plan should therefore:
• Require the highest achievable water efficiency standards for new homes and commercial development.
• Require water reuse, rainwater harvesting and greywater recycling.
• Require water-sensitive urban design.
• Align growth with long-term water resource availability.
• Ensure development does not adversely affect internationally protected sites and chalk stream catchments.

• Include higher or new standards for nature recovery and allocate sites for nature recovery or biodiversity enhancement?
Yes. The GNLP 2045 should contain stronger requirements for nature recovery than the minimum national requirements and should identify land for strategic nature recovery.
The consultation recognises that current biodiversity mitigation and enhancement can be fragmented and piecemeal, while national policy is increasingly focused on strategic, landscape-scale recovery.
The plan should:
• Allocate and safeguard strategic areas for habitat creation, ecological restoration and nature recovery.
• Use the emerging Local Nature Recovery Strategy and Greater Norwich Green Infrastructure Strategy as key spatial evidence bases when identifying growth locations and environmental priorities.
• Require developments to contribute to ecological connectivity, not simply deliver site-specific Biodiversity Net Gain.
• Requirement developments within an ACB area of the LNRS to deliver a higher level of BNG (20%).
• Enhance river corridors, wetlands, grasslands, woodlands and species-rich habitats.
• Establish measurable targets for habitat creation, ecological connectivity and biodiversity outcomes.
• Ensure new development contributes to recovery of protected sites and wider ecological networks.

• Identify sites for enhanced green infrastructure, including Suitable Alternative Natural Greenspace, and set local green infrastructure standards?
Yes. The GNLP 2045 should identify strategic green infrastructure sites and establish clear green infrastructure standards. The Greater Norwich Green Infrastructure Strategy provides an excellent foundation and should be embedded within the spatial strategy.
The plan should:
• Allocate land for strategic green infrastructure corridors.
• Identify and safeguard Suitable Alternative Natural Greenspace (SANG) where required to reduce recreational pressure on protected habitats.
• Improve access to natural greenspace for existing and new communities.
• Establish locally justified green infrastructure standards where these provide stronger outcomes than national standards.
• Ensure green infrastructure is multifunctional, providing biodiversity enhancement, active travel routes, climate adaptation, health benefits, flood mitigation and recreation.
Green infrastructure should be treated as essential infrastructure rather than an optional enhancement.

The GNLP 2045 should promote a design-led approach that delivers sustainable and resilient places while respecting local distinctiveness.
Sustainable design
The plan should:
• Require development to be designed around walking, cycling and public transport.
• Promote compact, mixed-use neighbourhoods with access to services and facilities.
• Integrate nature into development from the outset through green infrastructure, street trees, sustainable drainage and habitat creation.
• Support climate-resilient design that addresses overheating, flooding and water stress.
• Encourage efficient use of land while maintaining high-quality living environments.
Green infrastructure and trees
Tree canopy and green networks should become a defining element of future growth.
The plan should:
• Require retention of mature trees wherever possible.
• Deliver substantial net increases in tree canopy cover.
• Expand green corridors linking settlements, habitats and public open spaces.
• Incorporate nature-positive design principles into all major developments.

Overall approach
The GNLP 2045 should move beyond a model of simply mitigating harm and instead seek to deliver net gains for nature, climate resilience and community wellbeing. High-quality design should be judged not only by the appearance of buildings but by how successfully development creates healthy, resilient places that enhance biodiversity, strengthen landscape character and respond positively to Greater Norwich's historic environment

Overall, the proposed evidence base is comprehensive and covers many of the key issues facing Greater Norwich, including housing growth, infrastructure, transport, water resources, environmental capacity and potential new settlements. However, from a nature recovery and environmental capacity perspective, several studies should be expanded and some additional evidence should be commissioned.
Amendments to proposed studies
New Settlements Study
The study should emphasise environmental capacity and nature recovery opportunities, including:
• Strategic ecological networks and habitat connectivity.
• Local Nature Recovery Strategy priorities.
• Water resource availability.
• Nutrient neutrality constraints.
• Climate resilience and natural flood management opportunities.
Site suitability should be assessed not only on development potential but also on the potential to deliver landscape-scale environmental enhancement.
Infrastructure Needs Study
The study should explicitly recognise green infrastructure as essential infrastructure alongside transport, utilities, education and healthcare. It should assess:
• Strategic green infrastructure corridors.
• Suitable Alternative Natural Greenspace (SANG) requirements.
• Nature-based solutions.
• Habitat restoration opportunities linked to growth areas.
• Long-term management and funding arrangements for green infrastructure.

Water Cycle Study
The scope should include:
• Cumulative impacts of growth on internationally protected sites.
• Groundwater-dependent ecosystems.
• Chalk stream catchments.
• Long-term climate change scenarios beyond the immediate plan period.
• Nature-based water management solutions and wetland creation.

Strategic Transport Modelling
The study should place a strong emphasis on:
• Modal shift.
• Active travel accessibility.
• Carbon reduction outcomes.
• Public transport accessibility to employment, healthcare and education.
• Health and environmental benefits associated with reduced car dependency.

Additional evidence that should be commissioned
Natural Capital Assessment
A plan-wide natural capital assessment should be undertaken to quantify the value of:
• Carbon storage.
• Flood regulation.
• Water purification.
• Recreation and health benefits.
• Food production.
• Biodiversity and ecosystem services.
This would provide a stronger evidence base for balancing growth with environmental capacity.

Ecological Network and Nature Recovery Study
A dedicated study should identify:
• Existing ecological networks.
• Habitat fragmentation.
• Strategic habitat creation opportunities.
• Priority areas from the Local Nature Recovery Strategy.
• Areas where development would cause unacceptable ecological impacts.
This would help ensure that site allocations support rather than undermine nature recovery.

Climate Change Adaptation and Resilience Assessment
A specific climate resilience study should consider:
• Flood risk.
• Surface water flooding.
• Drought vulnerability.
• Urban heat island effects.
• Future climate scenarios.
• Nature-based adaptation opportunities.
Given the plan period extends to 2045, climate resilience should be a central consideration.

Green Infrastructure and Accessible Nature Assessment
Although there is a strong existing evidence base, additional work should identify:
• Deficiencies in access to natural greenspace.
• Areas requiring SANG provision.
• Opportunities to strengthen strategic green corridors.
• Health inequalities related to access to nature.

Environmental Capacity Study
A cross-cutting environmental capacity assessment should bring together evidence on:
• Water resources.
• Wastewater constraints.
• Nutrient neutrality.
• Biodiversity.
• Recreation impacts.
• Landscape sensitivity.
• Climate change.
This would help determine the realistic scale and distribution of growth that can be accommodated sustainably.

Summary
The proposed evidence programme would be strengthened by:
• Expanding environmental considerations within the existing studies.
• Commissioning dedicated evidence on ecological networks, natural capital, climate resilience and environmental capacity.
• Using the Local Nature Recovery Strategy and the Greater Norwich Green Infrastructure Strategy as key spatial evidence to guide future growth.
This would help ensure that the plan is not only capable of accommodating growth, but also capable of delivering measurable improvements for biodiversity, climate resilience, water resources and public access to nature.

Overall, the consultation provides a good overview of the key issues facing Greater Norwich and identifies many of the challenges associated with accommodating growth to 2045. However, several overarching matters should receive greater emphasis as the plan progresses.
Environmental limits should underpin the growth strategy
The GNLP 2045 should be guided by a clear understanding of environmental capacity. Growth should be planned within the limits imposed by water availability, wastewater treatment, nutrient neutrality, flood risk, climate change and biodiversity considerations. These matters should be treated as fundamental spatial constraints that shape the strategy, rather than issues to be addressed after growth locations have been identified.
Nature recovery should be a strategic objective
The plan should place nature recovery alongside housing delivery, economic growth and climate resilience as a core objective.
In particular, the GNLP 2045 should:
• Deliver measurable improvements for biodiversity.
• Support implementation of the Local Nature Recovery Strategy and the Greater Norwich Green Infrastructure Strategy.
• Identify strategic areas for habitat creation and ecological restoration.
• Strengthen ecological connectivity across the Greater Norwich area.
• Ensure development contributes positively to the recovery of wildlife and ecosystems.
Green infrastructure should be treated as essential infrastructure
Green infrastructure should be recognised as critical infrastructure in the same way as transport, schools, healthcare and utilities.
Climate adaptation requires greater emphasis
The plan recognises climate change, but future work should place equal weight on adaptation as well as mitigation. The GNLP 2045 should ensure that new development is resilient to:
• Surface water flooding.
• River flooding.
• Water scarcity.
• Heat stress.
• Extreme weather events.
Nature-based solutions should be prioritised wherever possible.
Health and wellbeing should be embedded throughout the plan
Access to nature, active travel, clean air and high-quality green space all contribute significantly to public health outcomes. The plan should better integrate environmental and health objectives and recognise the role that well-designed places can play in reducing health inequalities.
Monitoring and measurable outcomes
The consultation highlights the importance of measurable outcomes for the plan. The GNLP 2045 should include clear indicators relating not only to housing and employment delivery but also:
• Biodiversity recovery.
• Habitat creation.
• Water consumption.
• Carbon reduction.
• Active travel uptake.
• Accessibility of natural greenspace.
• Tree canopy cover.
• Climate resilience.
This would enable progress towards the plan's objectives to be monitored transparently over time.
Overall comment
The GNLP 2045 presents an important opportunity not only to accommodate growth but to leave Greater Norwich in a better environmental condition than it is today. The plan should therefore seek to deliver nature-positive, climate-resilient growth that enhances biodiversity, strengthens ecological networks, improves access to nature and supports healthy communities, while ensuring that development remains within environmental limits.