I was trained as a biologist specialising in Ecology and Nature Conservation and lectured on these subjects at universities and colleges for 30 years
I was a member of the Colney Parish Meeting for 21 years and the Chairman of the committee for many years as the NNUH and the Research Park developed. In the early 1990s I produced an Environmental Assessment for then owners of Colney Hall.

Colney Parish has asked me to prepare a brief on local flood issues. This is because the property where I have lived for more than 30 years is beside the River Yare and I have examined flooding events in the area with great interest.

I feel that I have a sound knowledge base for commenting on major development proposals.

Great Norwich Local Plan proposals.
1. Colney
1. Policy GNLP0253
1a. Summary of Conclusions
Colney Hall is outside the approved 2015 Local Plan limit of development and development would have significant negative impacts on protected landscapes.
Colney parish objected to the inclusion of Colney Hall in 2018. Significant constraints have been identified under Housing and Economic Land Availability Assessment (HELAA). The proposal did not perform well scoring double negatives in a Sustainability Appraisal ( SA)
The facility proposed in the GNLP 0253 is not required to be located near the research park .
The 80 beds and 120 units of extra care housing is likely to add thousands more traffic movements on the B1108 an already congested road and would seriously impede through traffic to and from Norwich, UEA, the NNUH and the Research Park.

The Colney Hall 0253 proposal should be removed from the proposed GNLP 2021

1b Colney Hall Constraints
Colney a small village with more than 10% new homes, the site of Norwich Research Park, Norfolk and Norwich University Hospital, Spire Hospital, Global Clinic,GreenAcres burial site, two Anglian water substations , a large electricity substation and the Training Ground for Norwich City Football Club.

Parish Plans were announced in the 2000 White Paper and in 2009 a Parish Plan for Colney was produced. In 2015 the local Plan was approved setting the limit of development within the parish.
Colney Hall is outside the 2015 limit of development and development would have significant negative impacts on protected landscapes , the Yare Valley and Southern Bypass Landscape Protection Zone.

Recently, there have applications in Colney for an end of life hospice and the expansion of the GreenAcres site for a further 3600 burial plots. Despite concerns by the parish on flood related issues these applications have been approved subsequent to the GNLP proposals for Colney Hall.

The GNLP 0253 application proposes Colney Hall, (approx. 24.99 ha) is allocated for specialist housing for older people The site is to accommodate a dementia care unit of approximately 80 beds, approximately 120 units of extra care housing, and the conversion of Colney Hall. This application seems very similar in intent to the Priscilla Bacon Hospice (PBH) 2020/0578 application that has already been approved by South Norfolk Council in 2020.
Objections raised concerns regarding the extra amount of housing already planned for the area, removal of more protected green space and the impacts wildlife biodiversity. Norfolk Wildlife Trust stated constraints relating impacts on existing CWS 235 and impacts on floodplain may be significant and should be recognised as factors potentially making this allocation unsuitable for the proposed development.
Norwich Green Party comments on GNLP0253 and GNLP0158 (land within Yare Valley N of Watton Road) considered this land should be part of a Norwich Greenbelt and therefore protected from significant development so that it is retained as protected green space.

The Housing and Economic Land Availability Assessment (HELAA) for the site indicated a number of constraints relating to Access, Accessibility to Services, Utilities Capacity, Contamination and Ground Stability, Flood Risk, Market Attractiveness, Significant Landscapes, Townscapes, Biodiversity and Geodiversity, Historic Environment, Transport and Roads, Compatibility with Neighbouring Uses. A Sustainability Assessment was carried out and the proposal did not perform well scoring double negatives for air quality and noise, climate change mitigation and adaptation, Biodiversity, Geodiversity and GI, Education, Historic Environment and Natural resources, waste and contaminated land

However, although HELLA indicated that a suitable access may be possible, and that impact on local roads could be mitigated. I have found it difficult to find evidence in the GNLP 0253 proposal to support this conclusion. The nearest comparison site is the Priscilla Bacon Hospice 2020/0578 is smaller, 24 beds, and the application shows that the traffic generated would be some 851 movements a day. The GNLP0253 application for 80 beds and 120 units of extra care housing would seem likely to add thousands more traffic movements on the B1108, an already congested road and would seriously impede through traffic to and from Norwich, UEA, the NNUH and the Research Park.


2. POLICY BAW 2: Bawburgh and Colney Lakes
Bawburgh and Colney Lakes (approx. 73.5ha) is allocated for a water-based country park.
The 2009 Colney Parish Plan suggested a much less intrusive approach. Involving a network of circular walks linking the communities of Colney, Bowthorpe, Bawbugh, Hethesett, Little Melton, Earlham, UEA, NRP and the NNUH.

The BAW 2 land should be part of a Norwich Greenbelt involving the Yare Valley and protected from significant development so that it is retained as protected green space. Incorporated could be the existing County Wildlife Sites, Local Nature Reserve and possibly GreenAcres and Colney Hall.
This complex could form a important Wildlife Conservation Area with an information center for the wellbeing of local communities

Colney represents in microcosm the issues that face development in the Greater Norwich Area and throughout Norfolk.

3. Key Issues in the Area of Greater Norwich Local Plan.
3a Housing
Many residents will recall David Cameron on BBC’s Countryfile programme in 2012 stating,
“Our vision is one where we give communities much more say, much more control. The fear people have in villages is a great big housing estate being plonked down from above" .

Residents in towns and villages in the Greater Norwich Area and throughout Norfolk regularly learn of such new housing developments planned in their area. Who are these houses for? Certainly not for our local young people trying to own their own home as the so-called affordable homes in the development cost much more that most young people can afford. Developers frequently attempt to reduce the already low numbers of these "affordable homes " still further, arguing if they do not the scheme would not be profitable for the developer!!!!

It is puzzling why developers are still making applications for more development and getting approval by planners when there are some 31,452 un-built commitments in the GNDP area. Technically they are not all planning permissions - they are mainly site allocations in the JCS which will be rolled over into the GNLP)with a presumption therefore that planning permission will be granted.

An excuse often used by developers for new applications was the 5 year land bank requirement from local councils has not been achieved. However, throughout Norfolk the 5 year bank requirement has been achieved so why are some planners still approving new developer applications?

Norfolk is a very attractive county and it is understandable why people wish to live here. A reason suggested is that properties are cheaper in Norfolk. Why are they cheaper? This is because many developments are being built on greenfield sites where land is cheaper. Some developments like the Research Park and the Hospital are necessary but do we need more out of town retail parks and houses on greenfield sites?

A cornerstone of Norfolk's economy is agriculture. Nearly a quarter of the total of the national income comes from farming in the eastern region. Great swathes of productive farmland in Norfolk are going under construction projects. Satellite research showed East Anglian counties have had huge losses of farmland with Norfolk faring worst.

Unneeded and unwanted development is spreading like a cancer in the Greater Norwich Area and around our market towns and villages engulfing farmland when there are tens of thousands of unbuilt houses in approved housing allocations. Planners seem to be allow developers to "cherrypick" areas for new developments on greenfield sites

3.b Flooding
What has all this to do with flooding? The recent 2020 floods have been widespread including Norfolk and have raised awareness of flood issues and the risk of development. Around Norwich, for years there have been local and government action plans and flood assessment advising restricting development in most flood risk areas,
2011 Norwich Urban Area Surface Water Management Plan (SWMP); this includes groundwater susceptibility and covers most of Colney and shows the site has high susceptibility to groundwater flooding.
2018 Surface Water Management Action Plan (SWMAP). Department for Environment Food and Rural Affairs
2017 Greater Norwich Strategic Flood Risk Assessment (GNSFRA 2017).

The maps I have for the 1912,1968 and 1993 flood areas are incomplete and have probably been updated. Similarly with the groundwater susceptibility and surface water maps.
I have just read with interest the Greater Norwich level 2 Flood Risk Assessment but I have not been able to view Maps showing,
a. the extent of historic floods especially for the 1912, 1968 and 1993 events.
b. Groundwater flood susceptibility in GNLP area.
c. Surface Water flood areas.
The Level 2 assessment is extremely useful for examining specific sites. These give a series of pictures but a single map linking the all Groundwater flood susceptibility areas in GNLP and one for Surface Water flood areas would give a holistic picture for these matters in the GNLP area.
It is surprising that maps showing the extent of major floods have not been produced.

Unfortunately some planners and developers seem unaware of action plans and flood assessments and applications are approved in flood risk areas. Applications sometimes state flooding of a site once in a hundred years is a fairly unlikely flood event. However, the extent of historic flooding is not only important historically but has implications for development in the present day in river valleys. Around Norwich, for example, in the 1912 flood, houses in Wymondham were severely damaged along with the bridges at Bawburgh, Trowse and Lakenham. Records indicate major flood events occurred in river systems in the Norwich area in 1770, 1784, 1878, 1912, 1947, 1968,1993 , 2015, 2018 and 2020. This suggests that there is less than a 30 year interval between major floods and this interval is decreasing . Planning applications often do not mention this. Even a 30 year interval would make many developments unsustainable and the applications should be refused. Climate change is likely to increase the frequency of such flood events.
Unfortunately the Environment Agency flood map for three major flood events, only shows the extent of the floods in selected areas. Surely with modern mapping techniques almost all historic flood events such as the 1912 event can be mapped and made available to towns and parishes. This would give everyone an idea of the potential extent of flood areas. The groundwater susceptibility maps for the Norwich area is interesting because it indicates potential extent for flooding.

It would be informative if planners published information on the number and location of flooded properties in their area in the last 50 years and the dates when these properties were built.

3.c Norwich Western Link
For a year I worked for Bernard Matthews mainly at Weston Longville and have a fair appreciation of the area of the proposed NWL
If a Norwich Western Link ( NWL) is thought necessary it is not clear to many people why Option C was chosen by Norfolk County Councillors when a much cheaper and less environmentally damaging Option B(West) route is available.

1.Option B(west) and Option C both join the A47 at the same point, Wood Lane near Honingham. The economic benefits seem almost identical.
2. Option C involves a 720-metre-long viaduct over the Wensum and would cost £153 Million.
Option B(West) could utilise the existing bridge and needs no new crossing of the Wensum, no viaduct and costs £129 Million.

3. Environmental issues relating to NWL are extremely important.
Option C would destroy parts of important County Wildlife Sites (CWS) and permanently sever connections between other habitats along the route.
Option B(West) skirts past almost all CWS and important habitats and was identified by the Environment Agency as the least environmentally damaging route and would provide a bypass for Weston Longville

4. Another option that might be considered in view of controversy about an NWL is a single carriageway route for Option B(West) would have less environmental impact and at a cost of about £43 Million, the cheapest option of all.