6.19

Comment

Representation ID: 99119

Received: 11/11/2022

Respondent: Broads Authority

6.19 – again by only mentioning district and borough local plans, you don’t include the Broads Authority’s Local Plan. Say Norfolk LPA Local Plans.

Comment

Representation ID: 99337

Received: 18/12/2022

Respondent: Norfolk Wildlife Trust

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.