The Greater Norwich Local Plan (GNLP) is being produced by Broadland District Council, Norwich City Council and South Norfolk Council working together with Norfolk County Council through the Greater Norwich Development Partnership (GNDP).

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Representation 16540 on Evidence Base by Norfolk Wildlife Trust (Mr John Hiskett)

Support / Object: COMMENT
Document Link: Evidence Base - Interim Habitats Regulations Assessment (HRA)
Representation: We recognise that this is an interim report and are pleased to see that a good start has been made on gathering information to inform the HRA and in setting out the key issues that may affect designated sites. At this stage we wish to flag up what we consider are the two most important issues that need to be covered.
In our view, the most critical issue that needs to be addressed is in relation to the water cycle, both with regard to water quantity and water quality, particularly in relation to the Broads Natura 2000 sites. EA classifies the area as being under "serious water stress". The seriousness of this issue is also clear from the Anglian Water 25 year Water Resources Management Plan, which shows the Norwich and the Broads as one of the most water stressed resources zones in the AW area. As a result, consideration of impacts on water dependent sites should be a priority.
The second major issue that is directly related to development and the resultant increase in population in the Norwich area, is the increased recreational impact on designated sites. Since the JCS further evidence has been gathered, principally through the Visitor Surveys at European Protected Sites report that was carried out in 2015 & 2016. We are aware that this and other evidence on visitor impacts will be considered in detail however we would like to flag up the importance of considering impacts on sites further afield than the 8km that is often used in relation to impacts on designated sites, particularly in relation to coastal sites. It is also important to recognise impacts on less visited sites, such as components of the Norfolk Valley Fens (e.g Buxton Heath), which may contain habitats and species particularly sensitive to trampling and disturbance by dogs
We look forward to commenting in more detail on these and other aspect of the as HRA is developed.

Original submission

We recognise that this is an interim report and are pleased to see that a good start has been made on gathering information to inform the HRA and in setting out the key issues that may affect designated sites. At this stage we wish to flag up what we consider are the two most important issues that need to be covered.
In our view, the most critical issue that needs to be addressed is in relation to the water cycle, both with regard to water quantity and water quality, particularly in relation to the Broads Natura 2000 sites. EA classifies the area as being under "serious water stress". The seriousness of this issue is also clear from the Anglian Water 25 year Water Resources Management Plan, which shows the Norwich and the Broads as one of the most water stressed resources zones in the AW area. As a result, consideration of impacts on water dependent sites should be a priority.
The second major issue that is directly related to development and the resultant increase in population in the Norwich area, is the increased recreational impact on designated sites. Since the JCS further evidence has been gathered, principally through the Visitor Surveys at European Protected Sites report that was carried out in 2015 & 2016. We are aware that this and other evidence on visitor impacts will be considered in detail however we would like to flag up the importance of considering impacts on sites further afield than the 8km that is often used in relation to impacts on designated sites, particularly in relation to coastal sites. It is also important to recognise impacts on less visited sites, such as components of the Norfolk Valley Fens (e.g Buxton Heath), which may contain habitats and species particularly sensitive to trampling and disturbance by dogs
We look forward to commenting in more detail on these and other aspect of the as HRA is developed.


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