Object
Publication
Representation ID: 24505
Received: 22/03/2021
Respondent: Norwich Green Party
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
East Norwich
We suggest several additions to scope of development for to meet the area’s objectively assessed needs:
- ‘designed and built to zero carbon standards’
- ‘achieve traffic neutrality across the wider road network’
- green open spaces that include an extension to Whitlingham Country Park’
The revised paragraph 335 to read
“The masterplan will promote development of a high density sustainable mixed-use community designed and built to zero carbon standards, coordinate delivery of new transport infrastructure and services and achieve traffic neutrality across the wider road network, enhance green links and green open spaces that include an extension to Whitlingham Country Park, provide for a local energy network, enhance heritage assets, protect Carrow Abbey County Wildlife Site and address local issues including the active railway, the protected minerals railhead and flood risk issues.”
We support the creation of a proposed new sustainably built urban quarter in this location. Public consultation on a masterplan has yet to take place and the GNLP policy is the first opportunity for public comment. We consider that the GNLP summary description of the development omits important requirements
GNLP Policy 2 on carbon emission reduction in new development seeks the minimisation of energy demand but it needs to go much further. East Norwich should achieve zero carbon in a number of ways: calculation of Whole Life-Cycle Carbon Assessment; low impact construction; high energy efficiency standards that include optimal levels of thermal insulation, passive ventilation and cooling and passive solar design; production, storage and use of renewable energy on-site. The adopted London Plan (March 2021) sets an exemplar in stating ‘major development should be net zero carbon’ as part of the Mayor’s commitment to London becoming a zero carbon city.
Para 335 refers to ‘the delivery of new transport infrastructure and services’ network’. We are concerned that Norfolk County Council may propose new or improved external road links for serving East Norwich. When the County Council recently sold Carrow House on King Street to the City Council as part of East Norwich land assembly, the County retained ownership of a 10 metre corridor along its frontage. It leads us to worry that the County Council may consider widening or even dualling of King Street, the oldest road in Norwich leading out of the city, between its junction with Rouen Road and junction with Bracondale. The latter road leads to Martineau Lane roundabout, with roads leading off to Trowse, County Hall and Trowse bypass and it is busy at peak times. Neither would we wish to see a link road across the River Wensum to connect Bracondale/Martineau Lane with Harvey Lane. This idea, in effect the completion of the outer ring road, was proposed as an alternative to the completion of the inner ring road phase 3 in 1992. A road bridge would have a large number of adverse impacts: it would change the quiet suburban character of Thorpe, increase noise and pollution, reduce air quality, threaten marshland biodiversity and water storage capacity, reduce the amenity of the river Wensum, thereby undermining the River Wensum Strategy and conservation areas and add extra road capacity and encourage more travel by private car.
The brief for the masterplan includes an emerging development objective, ‘promotion of a low car environment’. We agree with the creation of this in order to create an attractive and safe community but we consider that it does not go far enough because it essentially refers to internal travel within the development. We are concerned about the impact of up to 4,000 dwellings on the wider road network. Hence, we propose ‘a low car development’ with strong measures that encourage car -free living. This would better achieve Net Zero and minimise the impact of East Norwich on the surrounding roads and wider road network.
We propose for investigation, the opening the former rail halt at Trowse for serving East Norwich and County Hall, with bus connections to UEA, the N and N Hospital and Norwich Research Park.
East Norwich would add to pressures on Whitlingham Country Park. The number of visitors has grown, creating conflicts between car-borne visitors and people travelling on foot and by bike along the narrow Whitlingham Lane and increasing pressures on the natural environment. East Norwich provides the opportunity to extend Whitlingham Country Park to cater for to cater for increased demands by incorporating and re-wilding suitable arable land close to the current park boundary.
Hence, we propose ‘a low car development’ with strong measures that encourage car -free living. This would better achieve Net Zero and minimise the impact of East Norwich on the surrounding roads and wider road network.
We propose for investigation, the opening the former rail halt at Trowse for serving East Norwich and County Hall, with bus connections to UEA, the N and N Hospital and Norwich Research Park.
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.