Object
Publication
Representation ID: 24107
Received: 19/03/2021
Respondent: Mr Bryan Robinson
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
13.1. My concerns regarding the inadequacy of the GNLP are tempered by the potential consequences of a free-for-all land grab if the plan is rejected and the JCS is considered out of date.
13.2. The residents of Greater Norwich have been badly let down in getting to this position for a plan which commenced in 2017 but will be concerned that the consequences of rejection of the plan on submission for inspection may be worse than those of accepting a substandard version.
13.3. The only solution I can see is to revise the Reg. 19 draft to align with the Reg. 18 proposals for target housing numbers; justify the job numbers target as realistic; remove the NWL from the plan and tighten up the policies and targets for the environment and climate change before submission to the Inspector for approval.
13.4. It is acknowledged that this may delay the submission but this would be less disruptive than rejection or a lengthy process of amendments later.
13.5. I am concerned that the 2021 Budget statement has changed the dynamics of East Anglia to which the plan as it stands cannot respond.
13.6. The growth ambitions for Greater Norwich have been severely weakened by the Budget announcement of the selection of Felixstowe as a Freeport which will cover a radius of 25 miles and encompass several major employment areas which will have the advantage of several business incentives and will be competing commercially with Greater Norwich and its associated export/import outlets of Great Yarmouth and Norwich Airport.
13.7. Literature for Freeport East is keen to stress the advantages to other areas highlighting Lowestoft/Great Yarmouth via the A12 and The Midlands via the A14.
13.8. Sadly the omission of upgrading the sub-standard northern section of A140 between Norwich and Ipswich and concentrating employment to the A11 Norwich to Cambridge corridor is likely to mean that Norwich will not be part of this growth generated by Freeport East.
See full representation for further details
1. Introduction
1.1. Comments have been invited under Reg. 19 of the Town and Country Planning Act(Local Planning) (England) Regulations 2012 on the soundness of the draft Greater Norwich Local Plan (GNLP) prior to submission to the Planning Inspectorate.
1.2. Soundness is defined as:
1.2.1. Positively prepared: The plan should be based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent which achieving sustainable development.
1.2.2. Justified: The plan should be the most appropriate strategy when considered against the reasonable alternatives, based on proportionate evidence.
1.2.3. Effective: The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities.
1.2.4. Consistent with national policy: The plan should enable the delivery of sustainable development in accordance with the policies in the National Policy Framework.
1.3. There are several reasons why I consider the Draft Plan in Reg. 19 is unsound but initially question the legitimacy of the changes in the Reg. 19 draft which fundamentally change the principles of the Reg. 18 consultation and on which the public are being denied representation which is patently unfair.
2. Fairness
2.1. It is trite law that a public body must adopt a fair procedure to decision-making to ensure that members of the public are given a fair and informed say before the decision comes into effect.
2.2. The draft Reg. 19 v 1.7 documents have significantly increased by 15% the housing provision over the life of the plan above the proposals in the Reg. 18 consultations initially citing Government proposals in the ‘Planning for the future’ consultation but later changing this to the fact that the 2018-based Government projections for Greater Norwich are higher than the 2014-based projections, as justification for going back on the intention for a further stage 18D consultation.
2.3. This approach of planning for the higher numbers in the 2018-based projections goes against the Government statement that the 2014-based projections should continue to be used in Local Plans.
For full representation view attachment.