Comment
Minerals and Waste Local Plan: Pre-Submission Publication
Representation ID: 99337
Received: 18/12/2022
Respondent: Norfolk Wildlife Trust
Representation Summary:
In addition to project level HRA, there is a clear need for the Plan to demonstrate that it won’t result in adverse effects on any European Sites (SPAs and SACs, whilst Ramsar sites are also afforded the same level of protection). The Plan's HRA should be able to demonstrate without reliance on deferral to the project level stage that it can avoid adverse effects on SACs and SPAs. Deferral to project level HRA leaves uncertainty which could result in an undeliverable plan if there are adverse effects only identified at the project stage.