0360/3053/R10 Policy

The strategic allocation for this area states: "Proposals for development must ensure that they will not place constraints on the operation of the existing rail connected asphalt and aggregates transhipment operation".

We would appreciate the addition of "and the operation of Carrow Yacht Club in the free movement through the site of heavy goods vehicles (specifically low loaders) and heavy cranes for recovery and launching of boats".

We would look for the Strategic Allocation to be amended:

"Deal Ground Development must also achieve the following site-specific requirements: 4) Proposals for development will ensure that these do not constraints upon the existing operation of Carrow Yacht Club, comprising its security and maintaining rights of way for vehicular access including low loaders and heavy cranes at all times".

All plans for the area should take account of the accessibility and security of the CYC site.

The club is concerned that proposals for improved access on foot and bicycle do not adversely affect the vulnerability of the site to intruders and would welcome that this to be taken into account when any plans are made for new bridges and rights of ways.

The Club has covenants with the landowners that protect our open access to the site and specifically for the access of heavy cranes and low loaders as has been our practice and custom since the mid 1950's. We would expect that this club be treated as the other enterprises on the Deal Ground, notwithstanding the covenants are in existence.

The strategic allocation for this area states: "Proposals for development must ensure that they will not place constraints on the operation of the existing rail connected asphalt and aggregates transhipment operation".

We would appreciate the addition of "and the operation of Carrow Yacht Club in the free movement through the site of heavy goods vehicles (specifically low loaders) and heavy cranes for recovery and launching of boats".

We would look for the Strategic Allocation to be amended:

"Deal Ground Development must also achieve the following site-specific requirements: 4) Proposals for development will ensure that these do not constraints upon the existing operation of Carrow Yacht Club, comprising its security and maintaining rights of way for vehicular access including low loaders and heavy cranes at all times".

All plans for the area should take account of the accessibility and security of the CYC site.

Minor points
• Page 12, point 6 of policy. Typographical/grammatical error: ‘heritage assets affected by the proposal on and off site including key views from and into the site’.
• Page 12, point 8 of policy – something to consider. You may wish consider biodiversity on this brownfield land that may establish or has been established over the years. Open mosaic habitat of intrinsic biodiversity value is a NERC Act habitat. Brownfield sites are listed as a Priority Habitat in Section 41 of the Natural Environment and Rural Communities Act 2006 (NERC Act), as ‘open mosaic habitat on previously developed land’. For more information go here www.buglife.org.uk/sites/default/files/Identifying%20open%20mosaic%20habitat.pdf and here jncc.defra.gov.uk/pdf/UKBAP_BAPHabitats-40-OMH-2010.pdf

We have a number of comments and observations. We do not think they are soundness issues, but the changes are needed, in our opinion, to make the plan better, clearer and more consistent. We believe they can be addressed as additional modifications.

Comments on Strategy document
Main points
The following points are quite important, but are not soundness issues. They do not affect the soundness of the Local Plan. They can however be easily added to the Local Plan to provide context, especially given the stance in the Plan that the sites in East Norwich are seen as one, including the part in the Broads. Other comments would aid clarity. These comments could be addressed as additional modifications.
• Policy 3
o The Built and Historic Environment – first bullet point – it states developers should be ‘undertaking a heritage impact assessment if significant impacts might arise’ – government guidance states that this is required for any application that affects any heritage asset or their setting – including locally identified heritage assets. Is the wording therefore needed and if so does it need re-wording?
o Policy 3 second bullet point – ‘public benefits’ might be better wording than ‘benefits’. Should this be re-worded to put the emphasis on avoiding harm to Heritage assets?
o Policy 3 - The Built and Historic Environment – last sentence states ‘importance of the heritage asset’, for the sake of consistency of terminology would ‘significance of the heritage asset’, as per the NPPF, be better?
o Policy 3 – Natural Environment – first para – it states ‘ancient trees and woodland’ should be protected. Could this be broadened out to include other trees which contribute greatly to our settlements and green spaces?
• The map on page 100 needs to show the part of the utilities site in the Broads. The preceding text talks about looking at the area as a whole, yet misses the bit of the Utilities Site that is in the Broads.
• Policy 7.1, page 105, there needs to be some acknowledgement in this policy, even if it is a footnote, to say that part of the Utilities site is in the Broads and that the entire area is being considered together, regardless of local planning authority administration boundaries.
• Para 205 – ‘The strategic approach to heritage is first to consider the potential location of development, for example does the location itself “fit” well in relation to adjoining settlements’. We are not entirely clear what this means. Does it mean that new development should relate well to its historic context?
• Para 205 - goes on to state that development should avoid intruding into important views of historic assets. Historic England guidance on the Setting of Historic assets (The Setting of Heritage Assets (historicengland.org.uk)) and numerous appeal decisions make clear that the setting of a heritage asset is much greater than views and it is the setting of heritage assets that need to be considered not specific views.
• Para 205 - Also ‘historic assets’ is used – should the term be heritage assets to ensure it correlates with the terminology defined in the NPPF?
• Para 207 – should this state ‘public benefits’ not just benefits?
• Para 207 – This paragraph recognises that in certain circumstances a balance will need to be struck between development and protection and this recognition is useful. It might be helpful if this section was weighted more towards protection of the historic environment, taking a precautionary approach. The NPPF states that substantial harm to grade II listed HAs should be exceptional and to SAMs or grade II* / grade I HAS should be wholly exceptional (para 194). Equally para 195 of the NPPF states applications should be refused where a proposal will lead to substantial harm unless there are substantial public benefits that outweigh that loss or all of 4 tests can be met.
The reason for the following is not explained and is different to the NPPF. Depending on what is meant, it could affect the setting of the Broads. We would welcome some explanation around the wording used and also its justification.
• Policy 7.4, page 117 seems to imply that rural exception sites or entry level exception sites can be ‘well related’ to settlement boundaries. The NPPF says that such sites should be adjacent. Why is this approach being changed? It does not seem to be explained anywhere in the document. What is well related as well? How far from a settlement boundary can a development be? Depending on what is meant, this could affect the setting of the Broads and we may strengthen the status of our comment later in the examination process. Perhaps of relevance are the changes to the NPPF that are proposed to the current paragraph 172, proposed paragraph 175: ‘The scale and extent of development within these designated areas should be limited, while any development within their settings should be sensitively located and designed to avoid adverse impacts on the designated landscapes’.
The following points are not soundness issues, but the plan could easily be amended to include them. It seems logical to address these comments as additional modifications. They provide clarity and context and further useful information.
• Policy 2, bullet 5 – would welcome, perhaps in a footnote, reference to the landscape character assessment for the Broads, so it is clear that our LCA might be of relevance as well.
• Policy 7.1, page 106, last bullet point – you might want to have a footnote that refers to the local plan for the Broads and our policies on navigation.
Minor comments
Minor points for you to consider. These could aid clarity. They could be additional modifications.
• 10.3 – should this also refer to off shore wind’s on-shore infrastructure?
Typo and grammatical errors
Typos and grammatical errors for you to consider
• Page 105: Development of sites allocated in the East Norwich strategic regeneration area identified on the Key Diagram and defined on map 9 including Carrow Works, the Deal Ground and the Utilities Site will create a highly sustainable mixed-use gateway quarter accommodating substantial housing growth and optimising economic benefits. Development across the sites will provide in the region of 4,000 additional homes in the plan period and significant new employment opportunities for around 6,000 jobs. East Norwich also has the potential to act as a long-term catalyst for regeneration of the wider area, potentially including the following sites if they become available:
• Page 106: • creating an inclusive, resilient and safe community in which people of all ages have good access to high quality homes that meet housing needs, the provision of area-wide economic and social infrastructure and services, including (but not limited to) the creation of new employment opportunities, a new local centre, and a new primary school should need to be established’.
Comments on the sites document
The following points are quite important, but are not soundness issues. They do not affect the soundness of the Local Plan. They can however be easily added to the Local Plan to provide context. Other comments would aid clarity. These comments could be addressed as additional modifications.
• Throughout the various parts - as this is a planning document, no need to say ‘National Park’. Just say ‘the Broads’. There are many occurrences, so perhaps search for the term.
• It would be useful if all of the site allocation plans had street names on – the required standard for most planning applications is at least two street names.
• We note there is no mention of dark skies or limiting light pollution in the policies. The Broads has intrinsically dark skies, as can be seen at this map. We therefore recommend that wording could be added.
Norwich sites
The following comments are factual, observations, seek clarity, seek consistency or are typographical or grammatical. They are not soundness issues, but the comments could be addressed as additional modifications.

Observation:
As a matter of consistency. We note that para 2.198 says this ‘Given the site’s highly accessible location and the intention to provide new public transport links it is considered suitable to include car-free housing. In any event car parking levels should be kept low’. We note that other sites may say that the site is considered suitable for car free housing, but the wording in those instances does not go on to talk about the last part – car parking levels should be kept low. You may want to check to see if this wording is needed for other allocations.

0360/3053/R10
Main points
• Map page 15, this needs to show the part of the utilities site that is in the Broads. This does not affect the soundness of the Local Plan. It could, however, be easily added to the Local Plan to provide context, especially given the stance in the Plan that the sites in East Norwich are seen as one, including the part in the Broads.
• We request that wording like that at 2.134 is included in the supporting text for CC4b. ‘2.134 The site lies adjacent to the River Wensum. It is recommended that developers engage in early discussions with the Environment Agency and the Broads Authority’. Considering what is written at 2.134 and considering the similarities in the location of the site, it seems logical to be consistent and include the Broads Authority as suggested.
Minor points
• Page 12, point 6 of policy. Typographical/grammatical error: ‘heritage assets affected by the proposal on and off site including key views from and into the site’.
• Page 12, point 8 of policy – something to consider. You may wish consider biodiversity on this brownfield land that may establish or has been established over the years. Open mosaic habitat of intrinsic biodiversity value is a NERC Act habitat. Brownfield sites are listed as a Priority Habitat in Section 41 of the Natural Environment and Rural Communities Act 2006 (NERC Act), as ‘open mosaic habitat on previously developed land’. For more information go here www.buglife.org.uk/sites/default/files/Identifying%20open%20mosaic%20habitat.pdf and here jncc.defra.gov.uk/pdf/UKBAP_BAPHabitats-40-OMH-2010.pdf
0068
Main points
• As part of point 1, refer to the scheme making the most of its riverside location, as is stated in other policies. This is a matter of consistency. 0401 and GNLP0409AR for example have good wording in point 1 that can be used. It is not clear why this wording is in most, if not all other river side policies and not this one. This may simply be a drafting error. This would make the plan consistent.
• 2.30 – support the fact that early engagement with us is recommended, but not clear why the only reason is flood risk. Or does that part of the sentence only refer to AWS? It may need clarifying that in general, given its location, early engagement with the Broads Authority is recommended, rather than just saying to do with flood risk.
Minor points
• Typographical/grammatical error: ‘Missing full stop:(or if developed for student accommodation, a minimum of 125 student bedrooms). A small element of commercial, office, and/or educational use at ground floor level may also be acceptable’.
0401
Main point
• We request that wording like that at 2.134 is included in the supporting text for CC4b. ‘2.134 The site lies adjacent to the River Wensum. It is recommended that developers engage in early discussions with the Environment Agency and the Broads Authority’. Considering what is written at 2.134 and considering the similarities in the location of the site, it seems logical to be consistent and include the Broads Authority as suggested.
Minor point
• Typographical/grammatical error: 2.51: ‘The site is likely to accommodate at least 100 homes, or if the site is developed to include student accommodation (at least 250 bedrooms)’. Suggest removing brackets as the sentence is not really reading well or right as drafted.
Cc4b
Main point
• We request that wording like that at 2.134 is included in the supporting text for CC4b. ‘2.134 The site lies adjacent to the River Wensum. It is recommended that developers engage in early discussions with the Environment Agency and the Broads Authority’. Considering what is written at 2.134 and considering the similarities in the location of the site, it seems logical to be consistent and include the Broads Authority as suggested.
Minor point
• Typographical/grammatical error: 2.121: ‘Development of site CC4a should explore continued use/re-provision of the existing community garden facility’.
Cc7
Main point:
• 2.131: the trees seem to be in the Conservation Area and so have some protection. You might want to refer to that.

CC16
Main point
• 2.203 – we request that this is worded like 2.134 as follows: ‘2.134 The site lies adjacent to the River Wensum. It is recommended that developers engage in early discussions with the Environment Agency and the Broads Authority’. At the moment, what is worded only refers to the EA. Considering what is written at 2.134 and considering the similarities in the location of the site, it seems logical to be consistent and include the Broads Authority as suggested.
Minor point
• Does not mention about making most of riverside location in supporting text like other policies. The actual policy does. You may wish to add something to the supporting text to be consistent.
Urban fringe
The following comment is factual. It is not a soundness issue, but it seems logical to address these comments as additional modifications.
Factual update
• Para 3.75 – last sentence, amend as follows ‘the Church of St Andrew and its ruins’ – as both the church and ruins are listed.
Key service centres
The following comment seeks to improve context. It is not a soundness issue, but it seems logical to address these comments as additional modifications.
Main point:
• GNLP0378R/GNLP2139R, GNLP0312 and para 5.42 – please also mention dark skies of the Broads. The Broads has intrinsically dark skies. You mention the setting of the Broads, which is welcomed, but please add reference to protecting the dark skies of the Broads.
Broadland villages
The following comments are factual, observations, seek clarity, seek consistency. They are not soundness issues, but it seems logical to address these comments as additional modifications.
Main points:
• Cantley map, page 15 – show the Broads for consistency and to show the context.
• Horstead and Coltishall map, page 25 – show the Broads for consistency and to show the context.
• GNLP1001 – please also mention dark skies of the Broads. The Broads has intrinsically dark skies. You mention the setting of the Broads, which is welcomed, but please add reference to protecting the dark skies of the Broads.
• Coltishall, Horstead and Belaugh – should the Conservation Areas that covers parts of all three of these villages be mentioned in the text?
• Salhouse – again should the Conservation Area be mentioned – potential for limited impact on the wider setting of the CA at the site allocated in Salhouse.

We support the changes to policy 7.1 following previous representations we have submitted, notably on an increase in housing numbers, which have doubled from 2,000 to 4,000 homes to 2038. Also, given the complex nature of the East Norwich Strategic Regeneration Area (SRA), it is right that there is flexibility on the level of affordable housing requirements in general policy, allowing for the masterplan to address deliverability of the SRA. Additionally, the change in boundary of the allocation is also very much supported to include all land within the extant planning permissions 12/00875/O and 2011/0152/O; the May Gurney Headquarters site and within policy GNLP0360 (Deal Ground, Trowse Pumping Station and May Gurney). The regeneration area includes a CWS, which does not preclude development, and so a clear and unambigious policy is required to assess the acceptability of proposals that will affect it. We therefore propose that Policy 7.1 is amended to set out a clear benefit a development can provide, such as 10% biodiversity net gain. Please see our representation to Policy 3, which should be referred to in Policy 7.1.

To be sound the Local Plan should be consistent with national policy, which means that policies should be clearly written and unambiguous (see paragraph 16(d), Framework). The amendments put forward at question 6 ensures draft policy 5 is clearly written and unambiguous.

We are finding this allocation sound although we do have some comments for your review below.

This allocation includes the below 2 statements:

1) Site Allocation: ‘Site specific flood risk assessment must be undertaken prior to development and the design of the development will need to be flood resilient and incorporate appropriate mitigation measures in order to address flood risk from both river and surface water flooding.’
2) Policy 7.1 – ‘achieving high quality, locally distinctive, energy efficient and flood resilient design which addresses identified risks from river and surface water flooding and mitigates against potential sources of noise and air pollution and establishes strong built frontages along the River Wensum and the defining network of streets and spaces with the sites;’

The above statements are good, although there is no mention of the need to preclude development on a large part of GNLP0360 due to being Flood Zone 3b, and there is no mention on the need to not increase flood risk elsewhere and therefore provide flood storage. There is lots of mention of ‘flood resilient construction’ when this tends to mean the buildings can recover from a flood, while we would require buildings to have raised floor levels to prevent them flooding in the first place. It is however possible that perhaps this is just differing terminology and the intention is the same as us.

It is positive that the SFRA Site Summary Table includes lots of detail as to what is required to develop the site, so therefore this information should be covered here.

We continue to strongly advise that an HIA is prepared for the area now ahead of the EiP. This should also be used to inform the site capacity, the policy wording and the development of the masterplan for the Area.

Criterion 6
Reorder the sentences, moving the first sentence to the penultimate sentence.

Amend wording in third sentence to read ‘conserve or where opportunities arise enhance the character or appearance of the conservation areas’

Deal Ground
In criterion 3, replace ‘repair and reuse with be encouraged’ with ‘repair will be required together with a future maintenance scheme for the asset’.

Carrow Works
Re-frame second sentence of Carrow works bullet point 1 in a more positive manner to more closely
reflect the NPPF.

Add subheading for ATB site

Add ref at para 2.10 vii to unlisted Colman’s industrial buildings of historic interest and the potential retain and adapt these.

Thank you for consulting Historic England on the Greater Norwich Local Plan Regulation 19 Draft including The Strategy and The Sites. As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the conservation and enjoyment of the historic environment.

Our comments below should be read with reference to our previous comments dated 1.2.17, 15.3.18, 4.12.1, 26.4.19 and 16.3.20. Please also see our detailed comments in the attached tables, Appendix A in relation to The Strategy and Appendix B regarding The Sites.

SUMMARY
The Greater Norwich Local Plan covers the Strategy and Site Allocations. While commenting on the plan as a whole, Historic England is particularly concerned, for its implications for Norwich itself. Norwich is one of England’s great historic cities, and its architectural and historic character, and the sense of place associated with that, make a profound and wholly beneficial contribution to the city’s well-being.

In line with paragraph 185 of the National Planning Policy Framework (NPPF) it is important that the Plan should set out a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats.

We are instructed jointly by our clients, National Grid (NG) and RWE Generation UK plc (RWE), to make the following representations to the Greater Norwich Local Plan (GNLP) Regulation 19 Publication Draft. NG and RWE are the landowners and joint promoters of the Utilities Site at Cremorne Lane, Norwich. These representations continue our clients’ ongoing positive engagement with the Greater Norwich Projects Team throughout the local plan process and confirm the ongoing support for the site’s allocation in the GNLP as the examination of the plan draws closer.
National Grid and RWE are pleased that the Utilities Site has been carried forward and continues to form a part of the East Norwich Strategic Regeneration Area (Policy GNLP0360/3053/R10) also incorporating:
• Land at the Deal Ground, Bracondale and Trowse Pumping Station in Norwich and the former May Gurney site at Trowse in South Norfolk;
• Land at Carrow Works, Norwich;
• Land in front of ATB Lawrence Scott.

As highlighted in the publication draft, the principle of development on the site has already been accepted and it is expected that development will take place ‘within the time-period of this Local Plan’. As set out in our previous representations and most recently in the Statement of Common Ground, the site has been cleared and as such remains available, suitable and deliverable for development within years 0-5 of the plan. This is of course subject to ensuring that a suitable access arrangement can be funded and viably implemented. Discussions with Homes England and the East Norwich Partnership are ongoing with a view to agreeing a programme of funding. We therefore trust that once the access arrangements are confirmed, the Council will be receptive to a planning application coming forward for development within years 0-5.
In terms of density, whilst there is no specific number identified for the Utilities Site we wish to reiterate that the site will be capable of making a significant contribution towards the overall target of 4,000 new homes within the East Norwich Strategic Regeneration Area. The landowners will be seeking to maximise density on site, as encouraged by the GNLP Team, which will in turn assist with ensuring that a viable, deliverable scheme can be achieved within years 0-5 of the plan period.
As the next stage is the examination, we wish to express our interest in attending the relevant hearings, and participating in any discussions relating specifically to the Utilities Site, in order to continue positive engagement with the Council and the Inspector.
I trust that the above provides clarity on the landowner’s continuing support for the site allocation, without reiterating the content of previous representations. However, if any further information or clarification is required, please contact me. Otherwise, we look forward to discussing in more detail when the time comes.

1 Representation
1.1 We welcome the positive basis on which the overall Plan approach has been prepared, in particular the introduction of significant housing supply to contribute to the housing trajectory from strategic regeneration sites. It is clear from the published Trajectory that these sites will make a critical contribution to overall supply (both in terms of amount and resilience of supply) throughout the Plan period.
2 Soundness Issues
2.1 Based on the currently-published information, the Plan is not demonstrably sound in terms of justification, effectiveness and consistency with NPPF in respect of
(a) evidence of infrastructure need and associated costs;
(b) deliverability.
2.2 This gives rise to concerns about soundness for the purposes of NPPF35 and 16(b).
2.3 The Interim Viability Study did assess the deliverability of the ESRA with the scale of infrastructure contributions likely to be required. The scale of these contributions and the extent to which the
2.4 The NPS Final Viability Report (12 January 2021, FVR) adopts a generic 1,000 home typology (T11) but this does not relate to the ESRA and the FVR acknowledges that:
56. With regard to the assessment of ‘specific circumstances of strategic sites’ it is acknowledged that such sites will be impacted by strategic infrastructure costs over and above the usual developments costs of an average development site.
57. These strategic sites will be appraised in greater detail independently. What this Viability Appraisal achieves is to demonstrate whether the development of notional sites using an adjusted but standardised approach, can incorporate the emerging planning policies into the development costs while still achieving a satisfactory developers return and adequate land value to ensure land is bought forward for development.
2.5 As such, the evidence base for the Plan does not adequately demonstrate the following in relation to the ESRA:
(a) What the scale of burdens are intended to be in the ESRA (including the relative contribution of CIL); or
(b) How those burdens will affect deliverability.
2.6 That is contrary to both limbs of NPPF34.
2.7 The Plan should be clear about the scale of costs assumed for the ESRA, as well as amore appropriate land value and site preparation cost dynamics and constraints. It should not defer that to a SPD stage, which is not subject to EiP and which would create doubt about the requirements applicable to ESRA sites under Policies 5, 7.1 and GNLP0360/3053/R10.
2.8 This reflects the emphasis in the Planning Practice Guidance in relation to Local Plan preparation that:
Policy requirements, particularly for affordable housing, should be set at a level that takes account of affordable housing and infrastructure needs and allows for the planned types of sites and development to be deliverable, without the need for further viability assessment at the decision making stage.
2.9 PPG recognise that area-wide assessment is limited and "more detailed assessment may be necessary for particular areas or key sites on which the delivery of the plan relies". More detailed assessment on the issues above in relation to the ESRA is needed at this stage to properly support the welcome allocation of the ESRA as a regeneration area that is needed to make a substantial contribution to housing supply, effective use of previously developed land and environmental improvement over the plan period.
2.10 We also consider that the requirements for the ESRA SPD have not been adequately established in Policies 7.1 and GNLP0360/3053/R10. This relates to the scope, timing and scale of the masterplanning process and whether elements of it are Justified and will be Effective.

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.

See attachment for full representation (sections 6.3 - 6.8)

For Rosconn Strategic Land, please find attached the following documents and information:

1. Duly completed representation form
2. Representations to relevant policies of the GNLP and relevant parts of the evidence base
3. Site delivery statements including high level transport review note for Land South of Flowerpot Lane, Long Stratton (HELAA Ref. 4033/34)