Village Clusters Housing Allocations Plan - Alternative Sites & Focused Changes (Reg. 18)

We do not feel that option ii) is appropriate. The emphasis for planning locations of development should focus on brownfield and previously developed sites, including windfall sites, to meet local housing need whilst preserving the countryside. It is also important to give consideration to the potential impact of site development on local biodiversity and designated sites as well as ensuring that future allocations do not impede the delivery of the upcoming Nature Recovery Network for Norfolk. Whilst the Nature Recovery Network map for Norfolk is not yet available, it is anticipated within the lifetime of this plan’s production, and we would expect the plan allocations and policies to actively support the delivery of the county’s Nature Recovery wherever possible.
It is critical that County Wildlife Sites continue to be protected by policies within Local Plans as they are not afforded the legal protection given to SSSIs, SPAs and SACs and are vulnerable to indirect impacts. We therefore recommend that policy protection is always afforded to any allocations in close proximity to CWSs, through a requirement for these issues to be specifically addressed in an ecological assessment accompanying an application. The wording below taken directly from the Joint Core Strategy for Broadland, Norwich and South Norfolk (Adopted 2014) Policy 1, describes the aim to enhance such environmental assets.
‘..In areas not protected through international or national designations, development will: minimise fragmentation of habitats and seek to conserve and enhance existing environmental assets of acknowledged regional or local importance. Where harm is unavoidable, it will provide for appropriate mitigation or replacement with the objective of achieving a long term maintenance or enhancement of the local biodiversity baseline.’
In addition, Policy 3,The Natural Environment, of the soon to be adopted Greater Norwich Local Plan, states that:
“Development proposals should enhance the natural environment through:
• Being designed to respect, retain, and enhance, natural assets, taking account of local design and other guidance, such as Landscape Character Assessment;
• Avoiding harm to designated and non-designated assets of the natural environment, having regard to their level of significance (local, national and international) in accordance with the requirements of the NPPF and relevant policies in other Development Plan Documents and Neighbourhood Plans;
• Undertaking a relevant assessment (such as a landscape or ecological assessment) if impacts to a natural asset might arise”

We note that if allocated, this site will result in loss of the frontage hedgerow. 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.’
We recommend that clear and robust policy wording with respect to hedgerows/trees is included in this policy, such as the following: ‘The developer of the site will be required to ensure: ‘Protection of the trees and hedges on the site boundaries…’ . In exceptional circumstances only, where the developer has demonstrated that removal of any part of a hedgerow or a tree/s is absolutely unavoidable, then the policy wording should clearly set out high expectations for compensatory planting sited so that the existing ecological connectivity is not reduced. We recommend that policy wording should also require robust compensatory planting (delivering at least 10% Biodiversity Net Gain, regardless of whether the site is exempt from the mandatory national BNG requirements and also maintaining any ecological connectivity that the original habitat provided), 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.

We note that this is a greenfield site outside of the current development boundary. 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.’
We recommend that clear and robust policy wording with respect to hedgerows/trees is included in this policy, such as the following: ‘The developer of the site will be required to ensure: ‘Protection of the trees and hedges on the site boundaries…’ . In exceptional circumstances only, where the developer has demonstrated that removal of any part of a hedgerow or a tree/s is absolutely unavoidable, then the policy wording should clearly set out high expectations for compensatory planting sited so that the existing ecological connectivity is not reduced. We recommend that policy wording should also require robust compensatory planting (delivering at least 10% Biodiversity Net Gain, regardless of whether the site is exempt from the mandatory national BNG requirements and also maintaining any ecological connectivity that the original habitat provided), 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.

The option to extend the existing allocation homes at this site could have an impact on Broom Heath CWS, which is around 200m away. This site is potentially sensitive as highly accessible heathland. There is a strong body of evidence showing how increasing levels of access can have negative impacts on wildlife. Issues are varied including disturbance, increased fire risk, contamination and damage. We recommend that policy wording should reflect the proximity to the CWS and any applications should review any potential indirect disturbances to this site in an ecological assessment, in particular with respect to potential visitor pressure impacts.

We note that this is a greenfield site outside of the current development boundary. 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.’
We recommend that clear and robust policy wording with respect to hedgerows/trees is included in this policy, such as the following: ‘The developer of the site will be required to ensure: ‘Protection of the trees and hedges on the site boundaries…’ . In exceptional circumstances only, where the developer has demonstrated that removal of any part of a hedgerow or a tree/s is absolutely unavoidable, then the policy wording should clearly set out high expectations for compensatory planting sited so that the existing ecological connectivity is not reduced. We recommend that policy wording should also require robust compensatory planting (delivering at least 10% Biodiversity Net Gain, regardless of whether the site is exempt from the mandatory national BNG requirements and also maintaining any ecological connectivity that the original habitat provided), 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.

The site is within Geldeston Meadows SSSI Impact Risk Zone and, as a development of over 10 units, is likely to require consultation with Natural England. Geldeston Meadows SSSI is a floodplain grazing marsh which is currently in an ‘unfavourable condition’ and a small part of which is in an ‘unfavourable declining’ condition. It is also a component of the Broads SAC/Broadland SPA and within the Impact Risk Zone.
National Planning Policy Framework (NPPF) 180 states ‘When determining planning applications, local planning authorities should apply the following principles: ….b) development on land within or outside a Site of Special Scientific Interest, and which is likely to have an adverse effect on it (either individually or in combination with other developments), should not normally be permitted…..’
In light of the above policy, we recommend that policy wording in VC GIL1 should reflect this. Any applications should review any potential indirect disturbances to this site in an ecological assessment, in particular with respect to potential visitor pressure impacts.
This site is also noted as being amber for great crested newts, a protected species. We therefore recommend that any policy wording also includes reference to the need for an appropriate great crested newt assessment prior to determination, in order to ensure that the allocation is supported by the appropriate ecological evidence.

This is in close proximity to Swardeston Common CWS which is well used for recreation and has a network of paths running through it. Two of the ponds within this CWS are already severely affected by run-off from the road. The allocation for approximately 40 dwellings could potentially cause additional adverse impacts on this CWS due to increased visitor pressure.
Policy wording should reflect the proximity to the CWS and any application should review any potential indirect disturbances to it in an ecological assessment.

We support the following policy wording and recommend that this is retained – “Appropriate landscaping of the north and west boundaries, to contain the development and integrate it with the wider countryside, and the protection and enhancement of the existing vegetation along the south west boundary”.

We note that the Sustainability Report states that “biodiversity value of the site must be understood in the context of its position in the wider landscape. The Regulation 19 supporting text explains: “A network of off-site ponds exists in proximity to the site and development of the site should ensure ongoing connectivity between these ecological features. Similarly, appropriate measures will need to be taken to ensure the continued protection of the protected horse chestnut tree on the site frontage...”
We recommend that wording is included within the policy to ensure ongoing connectivity between the network of off-site ponds.
We support the following policy wording and recommend that this is retained – “Retention and protection of the horse chestnut tree on the site frontage which is subject to an existing Tree Preservation Order”.
We note that this is a greenfield site outside of the current development boundary. 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.’
We recommend that clear and robust policy wording with respect to hedgerows/trees is included in this policy, such as the following: ‘The developer of the site will be required to ensure: ‘Protection of the trees and hedges on the site boundaries…’ . In exceptional circumstances only, where the developer has demonstrated that removal of any part of a hedgerow or a tree/s is absolutely unavoidable, then the policy wording should clearly set out high expectations for compensatory planting sited so that the existing ecological connectivity is not reduced. We recommend that policy wording should also require robust compensatory planting (delivering at least 10% Biodiversity Net Gain, regardless of whether the site is exempt from the mandatory national BNG requirements and also maintaining any ecological connectivity that the original habitat provided), 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.

We support the original policy wording: Landscaping of the southern and western boundaries of the site, respecting the need to integrate the site with the surrounding open rural landscape, as well as the retention and reinforcement of the existing hedgerow along the northern boundary” and recommend that this be retained. The reference to retaining and reinforcing existing hedgerow should also apply to the southern boundary.