Object
Publication
Representation ID: 24503
Received: 22/03/2021
Respondent: Norwich Green Party
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Policy 1: The Sustainable Growth Strategy
The GNLP is unsound. The number of new dwellings and deviation from the Government’s standard methodology using 2014-based projections is not justified and additional homes would increase carbon emissions.
The total provision of new dwellings has been raised from 40,541 to 49,500 with an unjustifiable increase in the buffer from 5%, as required by the NPPF, to 22%, a figure that the GNDP describes as ‘significant’ and has not been subject to public consultation. In addition, to this allocation, a minimum of 1,200 new homes will be provided in South Norfolk Village Clusters Housing Site Allocations document and 250 will be provided through allocations in the Diss and area Neighbourhood Plan, which are outside the purview of this consultation.
The experience of a high housing target in the Joint Core Strategy has been the difficulty of meeting a five- year housing land supply leading to developers winning planning appeals to build on greenfield sites unallocated in the JCS. Local councils are keen to grant planning permission for new homes, but the rate of delivery is in the hands of developers. Before the recent spurt in local housing delivery, Greater Norwich was below the five year housing land target. This was not due to any unwillingness on the part of the councils to grant planning permission, but to the slow rate of housing completions. Buildings rates have increased in the past three years leading to a current housing land supply for Norwich (March 2021) of just over 6 years which does not suggest a shortage of sites.
The GNP local planning authorities are keen on high housing targets for several reasons. Firstly, to deliver affordable homes, although ironically the Councils have experienced repeated problems of developers challenging housing viability which led for several years to considerable under-delivery of affordable dwellings. We have seen an improvement in the number of affordable homes being built in Norwich in the last three years, but this has been largely achieved by the City Council building council homes. Secondly, housing growth at a strategic scale attracts central government investment.
These above reasons do not justify inflating the housing figures because the downside is that the external environmental impacts such as carbon emissions and traffic growth are borne by society. Over 70% of the locations identified for the quantum of proposed housing are greenfield land which will increase journey distances and reliance on the private car. The SEA of the GNLP calculates that the proposed development of 49,492 dwellings within the GNLP would be expected to increase carbon emissions in the Plan area by 27.1% (565,079 tonnes based on 2018 estimates), for example due to allocating housing on a total of 84 sites located on previously developed land (1,091ha) . (Residual Effects from the GNLP). In response, the GNDP says that the increase in the number of residents is over-stated as a large proportion of need for new homes arises from the existing population and that the strategy for future development is to focus growth in the more sustainable locations.
The GNP underestimates the impact of new housing on greenfield land. These include the loss of agricultural land; the increase in buildings and hard paving, contributing to temperature rise, and the additional resources used by the population living in smaller households and occupying more housing such as car ownership, water usage and waste creation, the latter which is increasingly being sent for carbon intensive energy from waste incineration.
The GNDP argument that new homes will be located in more sustainable locations with the potential for non-vehicle modes of travel. However, this argument does not bear out the reality in Norfolk where even in large market towns such as Wymondham where a majority of even short journeys take place in the car. Norfolk County Council’s depiction of the County as a rural place which will remain reliant on the private car allows the Council to continue to argue for road improvements. The GNDP is trying to face both ways in claiming that housing in rural areas is sustainably acceptable and then arguing for improvements of the road network to support rural dwellers.
It is for this reason that the Green Group is opposed to Village Clusters amounting to the rural dispersal of housing to places with no or few services. South Norfolk Council’s argument has been that electric vehicles will be the panacea. However, this is not the case that electric vehicles will save the transport sector from having to addressing its mega carbon impact and allow business-as-usual- to continue. Dispersal of development adds to journey distances and to environmental impacts such as congestion close to urban areas, leading to demands for road building which together with embodies carbon in vehicle manufacture, involves considerable carbon in constructing new roads.
Weight should be given to draft consultation NPPF (Jan 2021) and the replacement policy on sustainable development for clause 11a):
‘Plans and decisions should apply a presumption in favour of sustainable development.
11a) ‘Plans and decisions should apply a presumption in favour of sustainable development. For plan-making this means that: a) all plans should promote a sustainable pattern of development that seeks to: meet the development needs of their area; align growth and infrastructure; improve the environment; mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects’.
We support the concentration of development in and around the Norwich urban area. However, we disagree with the allocation of a contingency site at Costessey for around 800 homes in relation to our argument about the excessive number of dwellings overall. It would be more sustainable to consider East Norwich which is within easy walking distance of the city centre, bus and railway stations.
We would like to see a greater reliance on windfalls on brownfield sites. It is highly likely that a generous number of windfall sites will come forward given the shake up of the economy, for example, loss of city centre retail and conversion of offices to dwellings. The GNLP states that evidence provides an estimated 4,450 homes from resulting from windfall development. Yet, only 1,296 dwellings have been allowed under windfalls, even though the GNLP acknowledges that ‘windfall development is likely to remain robustly high’.
Summary
We consider the GNLP to be unsound:
- Not positively prepared
- Not justified
- Not effective
- Not consistent with the NPPF
The GNLP Reg 19 would increase carbon emissions, contrary to the national legal target of net zero by 2050. The policy framework on climate change and local plans is addressed in the Centre for Sustainable Energy paper. Although climate change has been strengthened in the GNLP by the inclusion of a new climate change statement, it has been bolted onto to a previously prepared growth strategy and set of policies which are inconsistent with the statement and the evidence base on climate change. The GNDP is aware of this deficiency because they have agreed to review the Local Plan on climate change following its adoption.
The GNLP was not ready for the Regulation 19 stage. GNDP members had agreed to commission further work and undertake a Regulation 18C six week focussed consultation, but following the Planning White paper, they decided to proceed immediately to Regulation 19.
In our view, the Plan should not be accepted as sound but returned to the GNDP for further work to ensure soundness.
There are a number of matters which we consider to be unsound because they are
incompatible with the duty to proactively contribute to the mitigation of, and adaptation to, climate change under section 19 (1A) of the Planning and Compulsory Purchase Act 2004 which requires Local Plans to include:
“policies designed to secure that the development and use of land in the local planning authority’s area contribute to the mitigation of, and adaptation to, climate change”
The matters include:
- Absence of an overall carbon budget for Greater Norwich to 2050 consistent with the Climate Change Act 2008, supported by a strategy and policies in line with the carbon budget trajectory.
- High housing number which will increase development pressures on greenfield sites;
- Growth that includes dispersal of development to small villages which lack services and the possibility of new garden city settlements in open countryside distant from railheads (Thorpe Honingham, Hethel and Silfield).
- Sub-optimal energy efficient standards and renewable renewable energy generation
- Lack of attention to retrofitting of historic development.
- A transport strategy which would increase carbon emissions by caterimng for traffic growth and modest modal shift to bus, walking and cycling.
- Inclusion of a Norwich Western Link.
- Support for improvements to strategic highways.
Several of these issues are addressed in the Reg 19 response by the Centre for Sustainable Energy which was commissioned by Norwich Green Party (on sustainable communities, zero carbon development, sustainable transport, renewable heating, renewable energy generation and retrofitting of traditional and historic buildings).
The CSE paper forms part of our representation on Regulation 19.
We also endorse responses submitted by other parties who share the same concerns on a range of matters: CPRE, Norfolk Wildlife Trust, Wensum Valley Alliance, Dr Andrew Boswell and Client Earth.
They cover soundness matters at considerable length:
- Climate change
- Housing numbers
- Growth Strategy
- Green Wedges
- Green Infrastructure
Norwich Green Party Group’s representation mainly covers Transport Policy 4 which we consider to be unsound. We also make comments on a number of individual development sites: East Norwich, Anglia Square and on the smaller King Street Stores site.
The changes to the Plan that we would like to see are those we have set out in our previous representations on Regulation 18. They include:
- An overall carbon budget for Greater Norwich to 2050 consistent with the Climate Change Act 2008, supported by a strategy and policies in line with the carbon budget trajectory.
- A lower housing number (42,568 dwellings plus a 5% buffer) resulting in lower development pressures on greenfield sites;
- Growth concentrated in high density low car developments close to sustainable transport hubs, with a high concentration of growth located around Norwich.
- No dispersal of development to small villages which lack services.
- No new garden city settlements in open countryside distant from railheads (Thorpe Honingham, Hethel and Silfield).
- Protection of Green Wedges around Norwich.
- Development build to zero carbon standards that include renewable heating based on renewable energy generation
- Retrofitting of historic development.
- A transport strategy based on traffic reduction and a high degree of modal shift to bus, walking and cycling.
- Abandonment of a Norwich Western Link.
- No further major increase in road capacity.
For full representation see attachment.