Comments on the failure to adequately address sustainability principles in the GNLP
The joint councils involved in the Greater Norwich Area are currently consulting on the revised local plan. This envisages significant growth in the population of around 16% between 2018 and 2038. The basis of the development plan has to be supported by ‘sustainability principles’. This is one of the key underlying fundamentals which are supposed to guide development policy, yet at the same time, the County Council and other partners such as Anglian Water etc. are only too aware that there are massive water shortage problems in Norfolk, and East Anglia in general and have established a project the Sustainable Water Management Plan for Norfolk. From this evidence and other sources it is apparent that both our surface and ground water resources are being depleted by abstraction and drought issues faster than they can be recharged, and are projected to worsen, and that this is causing us to experience ‘poor’ quality ground water / surface water due to pollution and increasing concentrations of this due to diminishing volumes.
Clearly, if water is being used faster than it is being replenished then we are going to run short – in fact we already are, seriously so. Technology is not the answer as there are clearly no mechanisms in place to help to reduce demand sufficiently to compensate, and this is not a new problem as this issue has been discussed and known about since the 1990s and nothing has been done which would actually have any meaningful impact on the issues - who would pay and how basically.
There is no indication in the GNLP as to how this situation will be addressed in a measured, quantified, monitored and responsible manner which would indicate that this situation will not worsen, that damage to our health and environment (particularly by the drying out of key wetland habitats due to abstraction and the damage to Protected habitats and species) will not occur as a direct result of the amounts of growth provided for in the GNLP. As such the GNLP does not meet sustainability criteria and would be in contradiction of the Habitats Regulations.
Paragraph 162 of the Sustainable Growth Strategy seeks to promote Norwich as a key growth area to support the development of the national economy. It goes on to say that this will be compatible with ‘protecting and enhancing the environment’. In preceding paragraphs it states that both greenfield and brownfield sites will be developed. The aims of the policy are fundamentally in conflict and cannot be reconciled. It is not possible to achieve large scale growth and protect and enhance the environment. The site allocations chosen and the development strategy proposed clearly will urbanise and pollute (air, water, light and noise) what are currently rural areas. It also removes the appeal and attractiveness of rural areas and replaces it with unattractive, unappealing urban sprawl. This is not consistent with protection of the environment and it is not correct to state that it is. The plan therefore fails to demonstrate that it is sustainable in this respect.
The fundamental tenant of sustainability is that it should not damage or harm the environment in a manner which will result in cumulative net adverse impacts. The choice of a largely un-developed rural county to be targeted for large scale development and growth in preference to other areas of the Country which are already developed / damaged, and in need of regeneration / already have unemployment figures which suggest an underemployed workforce is again contrary to sustainability principles.
Similarly the choice of an area of the Country with limited infrastructure and positioned poorly geographically, making transport costs and mileage greater than for other areas is again contrary to good sustainability principles. Other areas of the Country are much better connected, have better existing infrastructure and clearly will have significantly lower adverse environmental impacts from development than those proposed in the GNLP. No sequential test to compare or even consider these issues is contained in the Plan, and therefore it fails the test of sustainability on this account.
The sustainability references need to be considered further. Large scale development as proposed will require responses in the form of new hospitals, schools, medical facilities and personnel, social services, older person’s services etc. These needs are referenced but not quantified and planned for within the GNLP and there are no indications where or specifically how they will be provided for although broad references to various sources of funding (none specific) are referred to. To propose large scale migration and development without ensuring that the means to support it are present and will be adequate / appropriately located is again risking an unsustainable community development and contrary to sustainability principles.
Impact on protected Habitats – Habitats Regulations
Under the Habitats Regulations, there is a requirement that development should not harm habitats protected by the Regs. There are numbers of sites within a short distance of the GNLP area – the Broads and North Norfolk Coast – which will be significantly impacted by increased population growth. There is no detailed assessment in the GNLP of the impacts on Protected Habitats, supported by empirical evidence to assess the impacts, or the value of
proposed mitigation measures. Commuted sums from some developments within a close radius of a specific site may have some offset capability to address impacts but this will be large scale, large area impacts which cannot be offset by commuted sums. Therefore the population growth projected will adversely impact on Protected Species and Habitats. Population growth allowed for in the Plan therefore exceeds that which can be supplied without harm to Habitats and Species and is contrary to sustainability principles and legislative requirements
Specific comments on site proposals
Site allocation GNLP 0466R / HNF2. The policy in the Broadland District LP states that only those employment uses which have ‘significant specific benefit from a use being located near the airport’ shall be permitted.
Clearly this is intended as a sustainability reason for the location of and otherwise intrusive and inappropriately located industrial estate which extends the developed area of Norwich approx. 1m further north than currently exists into open and undeveloped greenfield countryside.
However it is noted that this condition is not continued in the GNLP policy for this site and this is clearly an omission which is contrary to sustainability principles as the location of such a development to the north eastern side of Norwich – adding transport miles to any communication to this location from more or less anywhere else in the County or Country is contrary to such principles.