Support
South Norfolk Village Clusters Housing Allocations Plan (Reg. 19 Pre-submission Draft)
Representation ID: 3235
Received: 08/03/2023
Respondent: Anglian Water Services
The supporting text has clarified that the application has been recommended for approval subject to the applicant being able to address nutrient neutrality. For the reasons stated above for Policy VC NEW1, and the application has been through the relevant consultation process, we suggest that the following clause can be removed.
Remove policy text "Liaison with Anglian Water regarding foul water capacity and the potential need to phase the site to later in the plan period;".
See attached document.
Support
South Norfolk Village Clusters Housing Allocations Plan (Reg. 19 Pre-submission Draft)
Representation ID: 3263
Received: 03/03/2023
Respondent: Norfolk Wildlife Trust
We welcome the policy wording for hedgerows/trees in Policy VC ROC. We recommend that similar policy wording is applied to the policies listed below to ensure this approach is applied consistently across the Local Plan. Where removal of a tree or any part of a hedgerow is unavoidable, we recommend that policy wording includes reference to mitigation measures, reflecting the updated biodiversity duty required in the 2021 Environment Act to have regard to the enhancement of biodiversity.
VC BB1, VC BRE1, VC HAL2, VC SWA2, VC NEE1, VC WOR2, VC NEW2, VC SPO3, VC TAS1, VC BUR1, VC WIN1.
We particularly welcome the clear and robust policy wording with respect to hedgerows/trees in Policy VC ROC: ‘The developer of the site will be required to ensure: ‘Protection of the trees and hedges on the site boundaries…’ and Policy VC LMI: ‘Protection and enhancement of the ecological/biodiversity features of the site, including the established trees, hedgerows…’
We recommend that similar policy wording is applied to the policies listed below to ensure that the Local Plan consistently provides robust protection for all hedgerows/trees on these allocated sites, as appropriate. Where removal of any part of a hedgerow or a tree/s is absolutely unavoidable, we recommend that policy wording should also include reference to mitigation measures and ideally reflect the updated biodiversity duty required in the 2021 Environment Act to have regard to the enhancement of biodiversity.
VC BB1 (Barnham Broom), VC BRE1 (Bressingham), VC HAL2 (Hales and Heckingham), VC SWA2 (Swardeston), VC NEE1 (Needham), VC WOR2 (Wortwell), VC NEW2 (Newton Flotman), VC SPO3 (Spooner Row), VC TAS1 (Tasburgh), VC BUR1 (Burgh St Peter), VC WIN1 (Winfarthing)
Hedgerows (Priority Habitat)
Local Authorities have a duty under the NERC Act 2006 and the Environment Act 2021 to have regard to the conservation and enhancement of Priority Habitats in their decision making. Hedgerows are listed as a Priority Habitat under the requirements of section 41 of the NERC Act.
Also of relevance is: National Planning Policy Framework, (NPPF), 179: ‘-To protect and enhance biodiversity and geodiversity, plans should…62 b) promote the conservation, restoration and enhancement of priority habitats, ecological networks and the protection and recovery of priority species; and identify and pursue opportunities for securing measurable net gains for biodiversity.’
Trees
Trees are given some protection in legislation, for example, from the National Planning Policy Framework (NPPF). However, we strongly recommend that the Local Plan provides fuller, more detailed and comprehensive protection as described above.
National Planning Policy Framework (NPPF), 131: Trees make an important contribution to the character and quality of urban environments, and can also help mitigate and adapt to climate change. Planning policies and decisions should ensure that……. appropriate measures are in place to secure the long-term maintenance of newly-planted trees, and that existing trees are retained wherever possible.