Interim Sustainability Appraisal

GNLP0449: The proposal to build over 30 homes in Beighton is unrealistic. The village is classed as unsustainable and has no facilities (shop/ children's play facilities/ public House/ public transport). The proposed plan vastly exceeds the requirements of the village and will have adverse impact on traffic flow in Southwood Road. This Road is narrow and despite a 30mph speed limit has a real issue with existing traffic (see 'Speedwatch' returns) making it a dangerous rat run. A development of around ten to twelve homes avoiding the overhead power lines, would be more appropriate.

In general I support the objectives of the draft plan, and the sites suggested are all plausible. I hope that efforts are made to develop the large brownfield sites within Norwich (eg Anglia Square, Barrack St, Duke St) before encroachment on green field land. I accept however that in order to develop the Cambridge - Norwich corridor disproportionate growth in the Wymondham and Hethersett areas is inevitable.

I am in objection of the proposals for houses to be built on a very valuable green space Cottinghams Park hellesdon,site ref GNLP1019 this space is enjoyed by many dog walkers,children,runners and more members of this community,green space is in very short supply in hellesdon,and will be more so if and when the new houses are built.We need these areas for our welbeing,our good health and somewhere we can walk our dogs and our children can play safely.this area has been maintained and is getting very popular over time which shows how much it is needed for our growing community

I would query the sustainability of this Local Plan in delivering its vision. The existing Local Plan is subject to its statutory Local Plan Policies being ignored during the planning process, including those for delivering sustainable housing numbers, highway safety, flood risk as they can be overridden by the Guidelines from the National Policy Plan Framework (NPPF). For example, the 5-year land supply requirement. It seems the GNLP will require a significant amount of expenditure and time to be delivered yet it will be a document that is quite flimsy on implementation if challenged against the NPPF.

The Cambridge to Norwich corridor is the most logical development, but this should really have been combined with growing Norwich itself and it is puzzling why this was not a option !Brownfield sites must take precedence before agricultural land is taken. A massive increase in traffic into and out of Norwich
will be a consequence unless a variety of alternate transport is created in tandem and not afterwards.

Please note that the online submission required a simple "support" or "object" to the question of supporting the sustainability appraisal. Given we have a number of recommendations for changing and challenging the sustainability appraisal, it is felt that "object" is the best fit, although there are many elements of the document which CPRE Norfolk supports.

PREFACE

CPRE Norfolk is pleased to have the opportunity to respond to this consultation on the draft Interim Sustainability Appraisal document. We focus on the strategies and policies which most affect our interests and remit. In the order used in the Sustainability Appraisal Framework these are:

SA1 Air noise and light pollution; SA2 Climate Change; SA3 Biodiversity; SA4 Landscape and efficient use of land; SA5 Housing; SA11 Economy and jobs: SA12 Transport and access to services; SA15 Water. It is premature to comment on SA 13 the historic built environment until the draft further allocation sites are made at a later stage.

We respond in detail to chapters 7 and 8, also to chapters 2 and 4. We look to be constructive in our comments throughout and as such we have a final section on main conclusions and recommendations. There are two appendices. The first is on the GNDP-GNLP meetings and interactions in shaping the GNLP objectives. The second considers the constraints placed by central Government on a Local Plan. Decisions are made through other routes on major road schemes, water resource, housing requirements and offshore wind farms. We put the case that in assessing environmental impacts these should be borne in mind, although not a formal part of this sustainability process.

INTRODUCTION 

We responded to the draft Scoping Sustainability Appraisal and re-visited the final version as set out in the Scoping Report, issued on the 21st March 2017. We compared the forward process as described in the Scoping Report with the approach taken in this consultation draft Interim document. The prompt to look at the reports and minutes of the Greater Norwich Development Partnership (GNDP) meetings with the Greater Norwich Local Plan (GNLP) team, and the derivation of the sustainability baseline across two brief and inadequate  statements in the consultation document. We quote these statements in italics (not possible to use italics in our online submission): 

SA process and the GNLP. 1.7. Having taken account of representations made in response to the consultation a series of amendments were made to the Scoping Report. These amendments were agreed by the Councils between January and March 2017. In January 2017 [it was 30th] the GNDP agreed a draft vision and set of objectives against the draft SA objectives accompanied the report to the GNDP. In June [it was 23rd] the GNDP considered the emerging GNLP alternatives as regards Housing Numbers and Growth Strategy. A high level sustainability (appraisal) of these alternatives accompanied the report the report to the GNLP [must mean GNDP]. 

The need to do this was reinforced at the next page, and we quote again from the Interim draft. 

2. Sustainability Baseline.  2.1. The scoping exercise undertaken on the Greater Norwich Sustainability Appraisal Report established the scope and level of detail of information to be included. 2.2. For the sake of brevity, the final scoping SA report has not been repeated here. The section does, however, set out a summary of the baseline information and the forecast evolution of the baseline without the implementation of the plan. This information can be cross referenced with the key sustainability issues which are set out in chapter 3. This information has informed the evaluation of the policy alternatives considered in the emerging GNLP.  

In our view the sustainability baseline could have been written with little or no reference to the Scoping Report at all. The sustainability issues of the scoping report have been modified or changed, and a few key cases are entirely re-written. 

So in this context we discuss at Chapter 2 the scoping report  key pointers for this next, Interim stage; and then consider the dis-connect evident in the 'sustainability baseline'  in this consultation document.  At Chapter 4 we examine the GNDP-GNLP meetings (detail in Appendix 1), which at 30 January dealt with the interaction between the sustainability appraisal and the six GNLP objectives, which were approved and used verbatim at pages 17-21 here. 

However the major part of our response is to Chapters 7 and 8, where the reasonable alternatives are well presented and significant impacts discussed using the sustainability appraisal framework themes.  These mainly inform our final 'main conclusions and recommendations' section.  

At Appendix 2 we review the constraints on a Local Plan sustainability appraisal that arise from national policy, but interact with the GNLP remit. These are housing requirement, and above all, water resource and major road schemes. They are determined by separate procedures, but have a large environmental impact and a cumulative effect on the themes considered within the Local Plan sustainability process.  As such they should be borne in mind in the development of the Local Plan policy and strategies, and the consideration of reasonable alternatives. 

CHAPTER 2. THE DERIVATION OF THE INTERIM SUSTAINABILITY BASELINE: PARAGRAPH 2.3 

The Interim SA consultation follows the Scoping Report (21 March 2017) in the overall process, and of particular importance it is to have due regard to the summary of Sustainability Issues and their application in the Sustainability Framework. The Scoping Report sets out the Issues at Section 17, Figure 82, pages 137-140. This is a summary of Issues identified in Sections 1 to 15 on the various themes/topics. These are supported by a wealth of baseline information on each topic, and this provides a wealth of baseline information on the most recent data. As such it should inform and be applied in the Interim SA. The particular theme topics that are of interest to CPRE Norfolk are:  2 Climate Change; 3 Biodiversity; 4 Landscape; 5 Water; 6 Built Heritage, 12 Transport; 14 Economy and 15 Housing.  

Also of importance to the continuing process is the application of the Sustainability Appraisal Framework at Section 18, Figure 84, pages 143 to 151. The supporting text is at paragraphs 18.1.2 and 18.1.3 of the Scoping Report. We quote:  

The Sustainability framework aims to define what sustainable development means for the Greater Norwich Local Plan. It derives a set of objectives that derive from the context, baseline and issues identified in the previous sections and appendix 1. The framework provides a consistent way for the strategy, policies and potential growth locations to be assessed. 

The ultimate aim of the sustainability framework, therefore, is to ensure the Local Plan addresses environmental, economic and social issues. The sustainability framework identifies these features with, at this scoping stage before local plan policies have been drafted, suggestions for indicators to monitor their progress. 

We now turn to how this is dealt with by the Interim SA as regards its derivation of a Sustainability Baseline introduced at paragraphs 2.1 and 2.2, referred to in the Introduction. This text following at 2.3, from paragraph 2.3.1 to paragraph 2.3.40, has the title Summary of Baseline and Likely Evolution thereof without the implementation of the GNLP. This shows muddle and diversion from the Scoping Report. It takes themes in the same order of the sustainability Issues in the Scoping Report. However it conflates issues with baseline information from other sources, and adds a view of what might happen in the future that is not evidenced. Each theme becomes a brief and unbalanced summary across these three aspects. Overall it edits down issues or does not mention them, and clearly uses direct input from various sources on their theme interests.  

There is little numeric information other than that on Employment and the Economy which consists of little else, and based on their current data on business sector, from the LEP.  Air Quality is edited down on Issues, and adds (perhaps from Highways):  Air Quality in Norwich City Centre is likely to remain an issue during the plan period to 2036. Improvements may result from traffic management measures set out in NATS and prompted by the JCS and other measures prioritised by Norwich city centre AQMA Action Plan irrespective of the progress of the GNLP. In addition, Government action is expected to increase the uptake of ultra-low emission vehicles during the lifetime of the GNLP. This may help improve air quality in Norwich (and elsewhere).  

Climate Change at 2.34 and 2.3.5 is a total re-write. There is nothing on issues, but statements about the adopted JCS containing policies to address climate change issue; and considers what would happen in the absence of the GNLP.  On the theme Biodiversity there is an edit down on the issues and is less specific, and the two short sentences on Green Infrastructure are expanded to two paragraphs 2.3.7 and 2.3.8, again related to the JCS and being implemented through allocated and permitted development and through investment via the Green Infrastructure Plan. Landscape has been re-written and generalised, but at 2.3.10 does give an adequate summary of landscape sensitivities. However what is not recognised, and under-played in general in the SA process to date, is the lack of recognition of the ecological network in sustaining wildlife, and within that our river valleys are of the highest importance. Landscape and biodiversity go hand in hand in many places in Norfolk, and our river systems are supreme examples. 

In Appendix 2 we show the difficulties on water resource and increasing lack of sustainability in seeking to match supply to demand.  While the GNLP is restricted to water quality issues and efficient use, a read of the Anglian Water plan, Water Resource Management Plan 2015-2040 shows how over-optimistic the text is on the Water theme at paragraph 2.3.12. On housing there is again a re-write with the news that while the ratio of house prices to earnings peaked at the financial crash in 2007/08 at about 8:1, at 2013 the ratio was just under 7:1. However if does not mention that housing completions since the crash run at about half of the JCS planned trajectory, and while the needs target for affordable housing is 33% of total provision it is now less than half of that. These and other such issues, should be part of the baseline, and temper views on the next ten years. The Transport and Access to Services at paragraph 2.3.1 leads with all major road schemes such as the NDR being completed, what is planned, and how the proposed NDR 'Western Link' is a priority. This is not for the GNLP to promote. It does though impact on the environment (see our Appendix 2), and siphons off funding from the overarching objective on access to services in the sustainability appraisal framework, as set out in the Scoping Report.   

The themes of People and Communities, Deprivation, Health, Crime and Education are collectively re-written and extended and basically set out their individual interest with no comment on the environment. In the case of health there is some conflict in that the GNLP would be beneficial in terms of infrastructure; but come to an issue with the reference to nitrogen dioxide and particulates are a risk to peoples' health.   

We conclude with two points on this 'sustainability baseline'.  The baseline should have used the large amount of data in the Scoping Report and the Council's AMRs to re-visit and review the JCS and the progress made over the past ten years against policies, targets and delivery. From this would be seen there is the need to review these, and use to both provide a robust baseline, and a better perspective on what might happen in the future and improve on the forecasting. At the same time it should bring back the key issues, not bury them. 

The second point is that chapter 5, Methodology, indicates that there is a legal requirement to make use of the sustainability baseline as an aide when identifying reasonable alternatives and evaluating the significant effects on strategies and topic policies. In our view baseline presented in section 2.3 would not be fit for purpose.  

However in chapters 7 and 8, which we consider in some detail, it does not seem to have been used. There is however a rigorous assessment of theme alternatives against the sustainability appraisal framework, as set out in the Scoping Report and quoted above. This we welcome. 

CHAPTER 4, SECTION 4.6. GREATER NORWICH DEVELOPMENT PARTNERSHIP-GREATER NORWICH LOCAL PLAN INTERACTION:  MEETINGS JANUARY TO JUNE 2017 

The main function of the GNDP board is to drive and oversee the growth agenda for Greater Norwich in partnership with the three councils concerned: Broadland, Norwich City and South Norfolk. The New Anglia (Norfolk and Suffolk) Local Enterprise Partnership (NALEP) is closely aligned to the GNDP, and the LEP board members are predominantly of a business background, but also senior local politicians. The Leaders of Broadland and South Norfolk Councils are key members of the GNDP  (along with that of Norwich City), and that for South Norfolk was a LEP board member for the first five years of its existence, and recently succeeded by that of Broadland.  The chairman of the LEP for the first five years was a director of Anglian Water, who recently stepped down and his current roles include activities to support the implementation of some of the initiatives of the LEP.  

At Appendix 1 we give a background history to the growth agenda, and then focus in some detail on the meetings between GNDP and the Local Plan team in the period January to June 2017. This was prompted by the very brief summary on the SA process and the GNLP at paragraph 1.7. We amplify on this: 

CPRE Norfolk was one of the 'other relevant bodies' to respond to the draft scoping consultation held between 20 June and 15 August 2016 

There was a tracked version of the draft early in January to which a response could be made and following agreement with the councils the final version of the Scoping Report was issues on the 21 March 2017 

The January meeting at which the GNDP agreed the vision, the set of objectives for the GNLP, and evaluation of draft objectives against the draft SA objectives was on the 30 January, not 17 January 2017 as stated elsewhere. 

The 30 January meeting was a key meeting in the SA process, but at 21 minutes long in total, very brief. The two page report to members had at appendix 1 the vision statement and objectives, corresponding with this consultation text at paragraphs 4.4 and 4.5 respectively. Appendix 2 had the matrix of GNLP objectives and SA objectives essentially as at paragraph 4.6.3; but 4.6.3 has the addition of a numbered list of the sustainability appraisal 15 over-arching objectives. The remainder of appendix 2 for this Members' Report was the conclusions on the proposed GNLP objectives, and this commentary is set out in the consultation text at paragraphs 4.6.4 to 4.6.9, word for word.  

The six GNLP objectives as shown at 4.5.1 are two line sentences for each, essentially all worthy and aspirational good intentions that could have been written some decades ago and no doubt also in the future. As such they can only give a very 'high level' view in an evaluation against the sustainability objectives. They should have been derived against a realistic baseline of where we are now in the six areas, and what would be required to achieve them. The Delivery objective would clearly have benefitted from that. The objective for Delivery is: "To promote the delivery of housing, jobs and infrastructure supported with intervention mechanisms where the market is unable to deliver".  Following at number six is Environment: "To protect and enhance the built and natural environment, make best use of natural resources, minimise contributors and adapt to climate change". There is a direct conflict between numbers five and six, and in truth the use of the GNLP targets is too simplistic to carry out an adequate sustainability appraisal. 

CHAPTER 7. GREATER NORWICH LOCAL PLAN: OPTIONS FOR GROWTH - THE STRATEGY 

The methodology used in Chapter 7 and Chapter 8 is set out in the Methodology paragraphs 5.5 and 5.6. In responding at selected points on identifying and evaluating alternatives, we do so by paragraph number and do not quote any text verbatim unless it is necessary for the sake of clarity. We make one general statement on the Plan as a whole at this point. Much of the forecast data used is pre-June 2016 EU referendum, and we are entering a period of considerable uncertainty 'in this rapidly changing world'. Not all would confidently predict that the UK economy will see an uplift over the next ten years: quite possibly the reverse. We went through a similar loop with the JCS, and that was treated as though the 2007-2008 financial crash had not happened. As such the delivery on targets such as housing and jobs are not being met ten years on from their conception. Therefore, in developing the Local Plan caution should be exercised in not repeating this mistake. 

7.1 GNLP Strategy: Jobs Targets; and 7.2 Jobs - Evaluating Significant Effects 

7.1.2. Makes the statement that the East of England Forecasting Model (EEFM) provides a credible forecast of jobs growth between 2015 and 2036 of 27,400. The remainder of JCS planned growth plus the EEFM would represent a "baseline forecast" for a jobs growth scenario. Data presented in the early stages of this plan saw some significant swings in the forward job forecasts.  However as indicated at 7.1.4, anything lower than baseline would not be considered "reasonable". As such we accept the EEFM as credible for representing the baseline forecast for the plan purposes. 

7.1.3. The additional target of 13,000 jobs from the City Deal is understandable in terms of seeking high skill jobs, but not as an additional target number to the EEFM to make a jobs target of 45,390 jobs between 2015 and 2036. There is strong competition in the R&D and high skills sector. Also this is now more difficult as some programmes at UEA and NRP are dependent solely on EU funding (LEP report 22 February 2016). The Town Centres and Retail Study (2017) has an "enhanced"  jobs target of 45,000 between 2014-2036 and looks to be intensely and unrealistically relaxed about the rate at which internet shopping is eroding traditional retail outlets in major towns and market towns. 

7.1.4. CPRE Norfolk argued at the Region Plan Inquiry in 2005 for a re-balancing of the Norfolk economy to a much higher proportion of high skill jobs and less reliance on lower paid jobs in tourism and services.  As such we note that the last few words in the Economic objective of the plan: "To support and promote the growth of an enterprising, creative, broad based economy with high productivity and a skilled workforce".  We add though that re-balancing is critical. A large number of low skill jobs are more vulnerable to automation. In general these are in sectors which have the greatest impact on the environment, which in itself has a value to the economy, recognised in the Natural Capital Approach. In a similar vein, at 7.2.1, we agree with Alternative JT1, that additional jobs above the baseline forecast would have a significant negative impact on SA1 air and light pollution factors, SA2 in carbon emissions, and SA4 on the efficient use of land (and we add landscapes), as employment sites use mainly greenfield sites.  SA3 Biodiversity could also be an issue.  

7.2 GNLP Strategy: Jobs-Evaluating Significant Effects. 

CPRE supports JT2, that GNDP jobs target to be equal forecast jobs growth between 2015 - 2036. Note this excludes aspirational growth, and (see later) we seek a change in the GNLP objective. 

7.3 GNLP Strategy: Homes 

7.3.1. We agree that the Housing Requirement is a central element of any plan making process, and increasing the housing requirement would not only result in potentially increased impact from planned development, but would also increase the likelihood of a five year land supply deficit. A land supply deficit could result in ad-hoc release of land for housing (we would put a higher degree of certainty on these statements). We also agree with 7.3.3 on the elements required to establish housing requirements and policy alternatives, not least the impact of predicted windfall housing.  

7.3.4, 7.3.5. We note that the Government's standard methodology (14th September 2017) requires an increase from 39,486 homes between 2015 and 2036 (1,880 per annum,) as identified in July 2017 by the Central Norfolk SHMA, to give an OAN of 38,988 (2,052 per annum) from 2017 to 2036. However given that this 'methodology' increase will need to be accepted, we support the alternative at 7.3.7 that a reasonable alternative would be to for the housing requirement to equal the OAN. 

7.3.11. The SHMA considered additional housing to meet City Deal job growth. For the reasons we give at 7.3.1 above and at 7.3 on jobs, we would consider this should be absorbed within the total jobs target, and with it the alternative at 7.3.12.  Further, it would promote an increase in-migration of near retirement and non-economically active people, and pressure on health care.

7.3.20. Given historic trends in the GN area, and the past successful application in other districts, we are confident that over the period to 2036, a reasonable alternative would be for windfall housing to form part of delivery buffer of at least 20%. 

7.3.21. We consider therefore that, of the alternatives presented, the most appropriate and reasonable is scenario 2: GNLP Housing Requirement is equal to OAN, Delivery Buffer is approx. 20%. Forecast windfall housing forms part of the 20% delivery buffer. We welcome the fact that windfalls will be counted towards the delivery buffer under this option, but we note that when windfalls are added in, the buffer is likely to rise above 20%. Therefore, even allowing for NPPF requirements, this figure represents an over-supply, which could therefore be deducted from the housing allocation requirement.

7.4 GNLP Strategy: Homes - Evaluating Significant Effects. For the Jobs evaluation above we are pleased to see the use of the sustainability appraisal framework's over-arching objectives as required. We note these are numbered as plus 15, and assume this is because it could lead to evaluating the sum of jobs and housing, which are closely linked and should be 'matched'. We have some additional supportive comments on the table considering the SA objectives and the discussion of significant effects, and relative merit of alternatives. At SA3 on biodiversity and the functioning of wider "ecological networks". These are vitally important to wildlife, the full extent being only recently realised. We add that key to the networks are our river valleys, particularly so where arable land is dominant, which applies to much of the county. While river valleys are noted for their landscape value, closely related to this is the wildlife corridor aspect. This is partly why CPRE Norfolk advocates the introduction of a Green Belt for Norwich in the form of a "green wedges" model. At SA 15 there is discussion on water supply and disposal. Behind that lies the issue of water resource, and in the longer term we are not on a sustainable course. We discuss this in our appendix 2, and argue that plans that this should be borne in mind when considering alternatives for homes and jobs, and also be mindful that most of our most important wildlife habitats are water dependent on the same sources as for human use. 

7.5 GNLP Strategy: Infrastructure. We note at 7.5.1 and 7.5.2 that the growth identified and planned for in the JCS forms a substantial part of the housing requirement in this plan, and with the completion of the NDR and Thickthorn Junction, no further strategic improvements to support the overall growth to 2036 have been identified. 

GNLP Strategy: How Should Greater Norwich Grow? - Outline of the Reasons for Selecting the (Distribution of Development) Alternatives 

7.5.3, 7.5.4 We note that the options for the additional housing requirements (7,200 houses) range from a concentration of this development from around Norwich and the Built-up fringe to wide dispersal across Greater Norwich, and the alternatives are stated to be based on technical decisions and assumptions. 

7.5.5 As discussed above CPRE Norfolk is supportive that the Housing Allocations Requirement will be equal to the OAN; the Delivery Buffer will equal at least 20% (although we argue this should stay as close to 20% as possible), taking account of Windfalls. 

7.5.6. We look to see all outstanding housing commitments in the current Plan to be delivered by 2036. However we also propose that there is prioritisation to the use of brownfield sites within Norwich in particular (which has the greatest need), and that the current JCS commitments are completed before the any new, particularly greenfield sites are released. This phasing of sites is a central plank of our submission. The Scoping Report states that affordable housing needs make up 36% of the total need in Norwich, while it is only 17% in Broadland and 18% in South Norfolk (page 132). Further at 2014-15 the percentage of affordable dwellings completed had fallen to 14% across Greater Norwich (page 127). We add that with the increasing use of the internet, there could well be less retail and commercial activity and floor space requirement in Norwich, and with it an increase in the number of windfall sites, and as such an increase in the total delivery buffer. 

7.5.7. We agree the housing number requirement for the Greater Norwich Local Plan as in the table. The GNLP housing requirement from 2017 to 2036 is 28,988. With the delivery buffer of 24%, including windfall, the GNLP housing provision will be 48,465 houses; but note what we say at 7.5.6. Also, there should be effort to reduce the buffer to as close as 20% as required by the NPPF as realistic, when adding the windfalls to the 10% delivery buffer, which would mean the additional housing number could be reduced from the stated 7,200. With the buffer at 24% this represents an over-delivery of 4%.

7.5.8. The approach to defining distribution points 1 to 3. We support point 1: Maximise delivery on previously developed land (PDL) in Norwich and the built up areas of the fringe parishes. We also support Point 2: Maintain and enhance the vitality of Main Towns and Main [i.e. Key Service Centres] Villages by ensuring an appropriate baseline level of growth. Point 3: it should not be necessary to identify alternatives distributions for any remaining growth. However, we stress again that there is no need to build out any of these newly allocated sites until nearly all those already allocated under the current Plan are built out, if our suggestion for phased delivery is adopted.

7.5.10, 7.5.11. We agree with the rationale set out for PDL within Norwich and the built-up areas of the fringe. Also that at 7.5.12 and 7.5.13 for maintaining and (hopefully) enhancing the vitality of Main Towns and Main (Service) Villages. 

7.5.14. 7.5.15. We are not convinced on the effectiveness of a village cluster in terms of service and vitality. The suggestion to merge the three most rural categories into one in the settlement hierarchy ignores the reasons for these three separate categories. By maintaining three separate categories there is more chance of meeting the aim of creating sustainable settlements. Having to travel (i.e. usually drive) to the next village or hamlet to get to the nearest shop for example, must be recognised as being different from having a shop in your own village within walking distance. We suggest a more reasonable alternative would be to re-balance the numbers in this group by transferring 500 houses from the proposed service villages or village clusters to the Main Town and Key Services category and increase this from 1,000 houses to 1,500 houses. 

However, if our suggestion for phasing is adopted the need to build out any of these new sites before 2036 is greatly reduced, given the large number of already allocated sites under the existing Local Plan. A problem with the consultation papers is that phasing is not specifically offered as an option within the documentation. It will take almost 24 years before the existing Plan's allocation of 35,665 houses is used up. In these circumstances we consider that there is no reason why new sites allocated in the GNLP should not be phased. They would then be available for development should building rates increase, but if house completions remain at existing rates, as appears likely, these sites could stay on a reserve list.

7.5.16. We are supportive of the table on allocation requirements for alternative strategies; but as suggested above that for C (Main Towns and Key Service Centres) increase from 1,000 to 1,500; and that for D (Service Villages or Village Clusters) decreased from 1,000 to 500, whilst noting our comments regarding phasing and against Village Clusters.

7.5.17. It is right and required by the sustainability appraisal to evaluate the six distributional alternatives by use of the sustainability appraisal framework, using the 15 SA over-arching objectives. We make later make comment in Appendix B referred to at 7.5.19 and the geography involved. 

7.6 GNLP Strategy: How should Greater Norwich Grow? Evaluating Significant Effects 

7.6 The table provides the matrix to assess the six distribution options against the sustainability objectives; and the following text discusses significant effects and the relative merits of the six alternatives. We welcome the informative discussion on the sustainability objectives set out at pages 43 to 51. This provides a good basis for the iterative process as the Local Plan is refined on policies and sites, and marks meaningful continuity from the Scoping Report to this Interim stage. But there can be differing views on degrees of significance and the relative weighting given to the factors. These differences are clearly illustrated when one looks at the table assessing the same factors in the Greater Norwich Development Board Papers 23 June 2017, page 80, as this shows markedly different assessments from the table/matrix at 7.6 on page 42.  

Summary of Significant Effects. 7.6.1, 7.6.2 and 7.6.3 The brief summary of a detailed analysis of the six distribution options against the sustainability objectives and concludes that the choice at this stage appears to be finely balanced, with no alternative option better than any other. In our view the balance is heavily in favour of option 1, urban concentration (close to Norwich), especially when one also considers the table on page 80 of the Greater Norwich Development Board Papers 23 June 2017. The matrix/table on page 42 shows some different results from the table on page 80 of the 23 June 2017 GNDP Board Papers. While the most recent table confirms that overall urban concentration is a better option than dispersal, it is even clearer in the earlier version. The table on page 42 shows that urban concentration is better than dispersal in terms of: minimising air, noise and light pollution; improving well-being; reducing C02 emissions; mitigating the effects of climate change; protecting and enhancing biodiversity and green infrastructure; encouraging economic development covering a range of sectors and skill levels to improve employment opportunities for residents and maintaining and enhancing town centres; reducing the need to travel and promoting the use of sustainable transport modes. However, in terms of some of the other factors it seems that changes have been made to the table so that several options appear to be equal in terms of impacts, instead of showing what the earlier table demonstrated, which is that concentration was the best option and dispersal the least reasonable option. Further, we need to discuss housing and employment not just in terms of total numbers, but on the right type of housing to address need, and jobs linked to higher skills.

7.7. GNLP Strategy - Green belt - outline of reasons for selecting the alternatives 

We have previously mentioned the close interaction between landscape and biodiversity. In the planning system they have been, and still are, treated as two 'stand-alone' factors and compartmentalised matters. They are not, and this is best exemplified by the Norfolk Wildlife Trust's description of Living Landscapes. With this is a growing realisation of the importance of the ecological network. On current Core Strategies the best presentation of this is with the North Norfolk Core Strategy, at Policy EN 9 Biodiversity, see the six page appendix B.  This was adopted in September 2008, and since then there is a body of further evidence on the key importance of river systems (includes tributaries, ponds, wet fen and woodland, as well as the main river) in the ecological network. Recent work indicates that these are not isolated catchment areas, but at the watersheds between one river and another there are links between one river systems and the next; and this can be much enhanced by the restoration of farmland ponds. This relates to the whole of the county, not just within the GN area. As such, we consider that with the Duty to Co-operate, there should be specific policies to protect and enhance the ecological network. There is also support from the NPPF for this, see paragraph in the Nature Conservation chapter. This forms one of the exceptional circumstances for why a Green Belt should be created based in part on river and green corridors.

Growth, especially in the form of housing, is unprecedented, and is therefore a major change in circumstance. Historically, Norwich has maintained the feel of being a major city, but one which is relatively compact with plenty of green space. A Green Belt would help to maintain this, and in the form suggested (Green Wedges) by CPRE Norfolk would not prevent necessary development.

7.14. GNLP Strategy: Influence of the Norwich Urban Area and distribution of Growth - Outline of Reasons for Selecting the Alternatives 

This is essentially a consideration of whether to retain the Norwich Policy Area or not. The benefits of this longstanding policy are summarised at 7.14.1. CPRE have given support to this over many years and consider that the principles must be maintained. However with bedding down of the three councils into one JCS, and now Local Plan, we consider that calculating housing land supply on an individual district basis is an unreasonable alternative, as stated at 7.14.4. As such we support NCPA2 - that is to retain a Norwich centred area for some policy purposes, including recognition of the concentration of growth, to provide information to support promotion for economic purposes and to attract inward investment, shown at 7.15.  

However this is preceded at 7.14.5 "that if a Norwich centred policy were to be retained there would be also be potential alternatives for its geography. The exact locations are unclear; whilst any revised boundary would be unlikely to be significantly smaller than its current definition, the expansion of any boundary would be linked, to some extent, to the distributional strategy that is pursued". In this context it is critical to examine (see below) Appendix B on the six options for the distribution of the alternatives, listed at 7.5.17.  

7.15.1 to 7.15.4. We agree with the summary of significant effects. However the existence of options 2 to 6 opens up an entirely different and unsustainable scenario at the next plan review stage; and this might be embedded by the option selected now for the additional houses to 2036.  

Appendix B:  Distribution Alternatives 

We are supportive of the same repeated text that introduces each of the six options; and that while the requirement for new allocations is 7,200, there is a baseline position which provides for 3,900 homes to ensure that urban brownfields are maximised and rural needs are addressed.  Hence for each option there are 3,300 further dwellings to allocate. Our strong preference is for Option 1 Concentration Close to Norwich.  

Options 2 Transport Corridors is the least objectionable of the remaining five options, as in an empirical way with 3,300 dwellings to allocate, and the probability that they would be close to Norwich in any case. Option 3 Cambridge to Norwich Tech Corridor we reject as it includes a new settlement of 500 dwellings. The other three options are variations of dispersal, and we reject them all, especially Option 4, and add that Option 5 also includes a new settlement of 500 houses, this time in a Transport Corridor. Apart from the sustainability objection to a new settlement, there are no sound planning reasons overall in the new village proposal; nor in the pragmatic view, as there would be a delivery issue, as developers do not like time and complexity of larger sites, including agreement on the infrastructure required. 

The future scenario for Options 2 to 6 and how they would develop becomes untenable in looking at the maps that accompany each option, and we reference back to paragraph 7.14.5, and the geography comment. Only Option 1 presents an area which relates to the NPA area; while the area extends more than the NPA, this could be reduced, including the detached Long Stratton leg which the JCC Inspector in 2010 was not happy with. All other options are a radical departure from the NPA and its principles and objectives. They are comprehensively unreasonable.   

Option 2 presents a starfish shape scenario, with development appendages spreading out beyond Norwich along the A140 north, A1151, A47 east, A140 south, A11 south west and A47 west.  

Option 3 leaves Norwich to head down the A11 corridor towards Cambridge, via Theford, and to London.  

Options 4, 5 and 6 show two giant mushroom clouds to the north and south of Norwich, with a north east to south west angling.  

These maps are very revealing, and completely rule out 2 to 6 options in sustainability terms as a template for future distributional growth. They offer a choice between ribbon development along main roads, or two large areas of sprawl. In answer to the GNLP Strategy and the question how should Greater Norwich grow, CPRE Norfolk would support Option 1, or the retention of the NPA, and will make every effort to oppose option all the other options. It should also be borne in mind that if phasing were to be introduced for any new allocated sites, the likelihood is that no further growth beyond that planned for in the existing plan would actually be built out given the current, historic and likely future completion rates.

CHAPTER 8. GREATER NORWICH LOCAL PLAN: TOPIC POLICIES 

8.1 We note the opening statement "The thematic policies of the GNLP cover a number of broad policy areas.  Each of these policy areas has a number of alternatives relating to specific elements relating to specific parts of the policy. These alternatives are explained in the sections below". 

8.2.1 Economy. We quote: "The economic policy considers alternatives as regards to the overarching policy approach to the economy, the supply of employment land, the approach to windfall development and the retail hierarchy and focus on new comparison good retail space". 

8.2.2 "The City Deal has been signed with the Government to promote accelerated growth, the LEP's economic strategy identifies Greater Norwich as the region's main engine of growth with the Norwich Cambridge Tech Corridor initiative promotes further growth of high tech industries which are growing in significance nationally and internationally". We comment that while we support a focus on the high tech sectors it does not physically require ribbon development from Norwich to Cambridge, least of all in an electronic age. 

8.2.3 We quote again, with our emphasis: "The plan's draft vision promotes a strong economy for Greater Norwich. The economy objective is to support and promote the growth of an enterprising, creative broad based economy with high productivity and a skilled workforce. Therefore the GNLP will need to continue to provide a wide-ranging approach to supporting economic development and growth. This is the only reasonable alternative, as not including such a policy would not meet the objectives of the plan".  We suggest there is.  The second sentence reproduces the wording we show at Appendix 1, as when all six of the GNLP objectives were approved at the 21 minute GNDP meeting on 30 January 2017, and it needs more thought. 

To consider a reasonable alternative to "EC0 Continue with a wide ranging policy approach to promoting the economy", would also require a re-think on an alternative to the existing draft objective on Economy, such as: To maintain and enhance a broad based economy, with an added focus on the promotion on the growth of enterprising, creative and innovative sectors with high productivity and a skilled workforce.  The alternative to EC0 might then be EC1: Continue a wide-ranging approach to the economy, but prioritise the promotion of high tech high skill jobs. 

8.2.4 The summary of significant states that "Supporting economic development will inevitably increase light, noise and air pollution levels although the extent to which it occurs would depend on the type of development, which cannot be predicted at this stage. The type of business will also dictate the impact on carbon emissions, so the impact on SA2 cannot be judged at this stage". 

 We would also add to this SA3 on Biodiversity, SA 4 on land resource and SA 15 on water quality (and on water resource). In general high tech sectors will score better on the sustainability appraisal. In addition they are less vulnerable to job losses by automation, changes arising from an increases in online shopping, etc. They also have higher Gross Added Value, more job opportunities which reflects back to education, skills and training. There is a need to re-balance the economy, and become less reliant on retail and tourism, and less well paid jobs.  Finally a good natural and built environment helps to recruit and maintain skilled workers in a competitive market. 

Supply of Employment Land 

8.2.5 "The area currently has around 340 hectares of undeveloped employment land that is allocated or permitted. The Employment, Town Centres and Retail study concludes that, even to support an enhanced level of employment growth, the overall need for land is significantly less at 114 hectares". At 8.2.6 "There is no evidence to justify increasing the overall supply of employment land. Further increasing supply for which there is no demand increases uncertainty, risking investment to bring sites forward. It also increases the risk of encouraging uses that will be damaging to the city and town centres". 

At 8.2.8 CPRE considers that there are reasonable alternative policies such as to reduce the size of selected sites, and re-designate for housing; and/or for some sites reduce and apply criteria based policy for type of employment use, with a preference for high tech jobs. 

8.3 Access and Transportation 

This, like the Economy, for strategic transport, does not introduce any alternative other than the existing policy, which is at 8.3.3: TR0 A policy broadly supporting and promoting transport improvements.  We discuss this at some length in our Appendix 2, and how the environmental impacts for major road schemes are externalised into another separate process, with different criteria, and the added impact is not assessed within the sustainability appraisal for the Local Plan. A major DfT critera for funding are to support economic growth and facilitating the delivery of housing and associated development by opening up land. The decision criteria rest heavily on impenetrable and formulaic methodology for deriving Value for Money and Cost Benefit Ratio. 

8.5 Housing 

8.5.1 makes the introduction. "The GNLP Housing Policy will cover a number of different elements of housing including affordable housing provision, exception sites, housing mix, older peoples and care accommodation and provision for Gypsies and Travellers." 

8.5.2 to 8.5.7 Affordable housing provision threshold. CPRE supports the reasonable policy alternative AH1, where a proportion of affordable housing would be sought on all sites of five or more dwellings (as per current JCS Policy 4.) The principal reason is that it offers a greater chance of meeting the requirements for market towns and service villages. To raise the provision threshold to sites of 11 or more dwellings (AH2) would see the loss of many potential sites, this across a number of settlements that would otherwise qualify. 

8.5.8 to 8.5.12 Affordable Housing Percentage Requirement. We note the statement that "The 2017 SHMA conclusion is that a total of 11,030 affordable houses need to be provided over the period 2015-2036. Taking account affordable housing completions, this is 27% of the OAN for Greater Norwich derived from the recently published Standard Methodology. However, experience dictates that it is likely that not all sites will be able to deliver a policy-compliant level of affordable housing. Flexibility over affordable housing to ensure viability would need to be a feature of any affordable housing policy". On this last point we would argue for a more critical examination on the viability case presented by a developer, and subsequent changes that might be submitted.  The most recent AMR shows that with a JCS target of 33% the number of affordable completions are at half the target. We would agree with the statement at 8.5.9 that it is reasonable that the GNLP requires as follows: all qualifying sites to provide 27% on the assumption that the GNLP incorporates a reasonable amount of over-provision e.g. a delivery buffer; subject to a demonstration of viability, requiring more than 27% affordable housing on qualifying sites; and specify the affordable housing amount and, perhaps (we would omit the 'perhaps' ), phasing on larger sites on a bespoke basis, with a more general policy for smaller sites. 

Affordable Housing Tenure 

8.5.13, 8.5.14 and 8.5.15. We note that the 2017 Central Norfolk SHMA evidence is that the split between affordable/social rented dwellings and low-cost home ownership (LCHO) is at the ratio of 80:20. Also that "Subject to flexibility to ensure viability, the only reasonable alternative is to seek this tenure split on development sites as it is the only method to ensure that housing needs are met in accordance with the housing objective of the GNLP". CPRE would agree with this, and add also in accordance with the SHMA. We are therefore tentatively supportive of policy "AH6: Require all qualifying sites to provide the SHMA-evidenced ratio of rented and low-cost home ownership on all sites". However we can foresee difficulties arising from 'low cost' being too costly to permit the take-up of LCHO. This is especially so in many rural areas where salaries are low and market prices high. In those circumstances, the LCHO should be transferred to social rented rather than 'upgraded' to market housing provision. 

Exception Site Housing 

8.5.16, 8.5.17 AH8 states: "Don't allow any small-scale windfall sites for market housing adjacent to development boundaries, only for genuine "exception" sites (including an element of cross subsidy, if necessary)." This would rightly limit sites to where there is an identified local need. AH 7 would allow "small sites windfalls" to be permitted to development boundaries (i.e. sites of 10 or fewer). This would allow small developments of marketing housing also to qualify as exception sites, and with it would significantly increase development in small and rural settlements with few services. It would be another form of the dispersal in housing distribution, with the use of a significant amount of otherwise undeveloped greenfield land. As such we consider that AH7 is not reasonable. 

Climate Change 

8.6.1, 8.6.2 and 8.6.3. The GNLP's draft environment objective does not say "mitigate" against and adapt to climate change, but "minimise contributors" and adapt to climate change". The minutes for the 21 minute 30 January meeting of the GNDP show that one member requested this be changed to mitigate and adapt, and recorded that change would be made. But at page 17, 4.5, it has not been done. We add that the Scoping Report at Figure 84 - Sustainability Appraisal Framework gives the overarching "continue to reduce carbon emissions, adapting to and mitigating against the effects of climate change". A key indicator is carbon dioxide emissions per capita. Also the two line Environment objective omits the SA1, with the overarching objective to minimise air, noise and light pollution to improve wellbeing, with indicator of nitrogen dioxide and PM 10 particulates levels.  

The Environment 8.8.1. This states the identified reasonable alternatives for each of these sub-areas is set out below. 

Flooding: 8.8.2 states that it is important that the GNLP steers new development away from flood risk areas as far as possible and ensures that it mitigates against, and if necessary is adapted to, flood risk. However it does not explain how the 'steering' is done, and issues with some allocated land in the north east growth triangle indicate that this is not resolved. This is critical in terms of land allocation, as it assumes that at the next stage, the single FRI requires all relevant applications to undertake site-specific alternative Flood Risk assessments and to provide a surface Water Drainage study showing how SuDS infrastructure will be maintained in perpetuity.  

Nature Conservation. 8.8.6, 8.8.7. 8.8.1. There are two statements made. "There are potentially 'cumulative' recreational impacts on SAC/SPA and Ramsar sites resulting from the scale of growth needed within Greater Norwich. It is necessary to address these impacts". "There are considered to be two principal forms of mitigation; the provision of suitable alternative natural green space, to direct additional recreational trips away from sensitive sites, or direct mitigation for SACs/SPAs and Ramsar in the form of a management and monitoring strategy to increase the resilience from recreational impacts".  Our response is that the "potential" should clearly be "will happen"; added green infrastructure is very different from these sites, and it is their special interest which visitors come to see, not a piece of GI; there is no way to mitigate the impacts, other than place strict limits on access, including a direct control of the numbers of visitors, and 'no dogs', at least on a seasonal basis. In addition, the numbers of day visitors will be much greater than local residents (unless a permit scheme is introduced), not just within Norfolk. The GNLP can give support to major road schemes . The dualling of the A11, the near completion of the NDR, programmed improvements on the A47, and a county council priority for a Norwich Western Link road, will see much more visitor pressure long before the 2036 timeline. Visitors will come from up to 150-200 miles away. Support to such schemes by the GNLP ought to take this impact into account in their sustainability appraisal. Finally we add that in addition to people numbers there are other key sustainability issues, not least water resource and quality. Nearly all of these high designated sites are water dependent. 

Landscape 8.9. See our comments on Green Belt at 7.7.   

In our view this topic section is brief and incomplete. It adds to our case that the draft GNLP objective for Environment should be re-visited, along with the other five objectives, particularly Economy. They need to be include all aspects, and be at least half a page. A sustainability appraisal on an objective of two lines is so high level and generalised as to be meaningless. 

Energy 8.10. 8.10.3 states that there it should be considered reasonable to have a policy similar to the JCS, but remove that relating to wind energy to avoid conflict with recent Government policy. We would also add with the dramatic increase in off-shore wind farms, such as Orsted and Vattenfall, it is clear that the onshore cabling route will result in a range of environmental impacts, with those on biodiversity not being well recognised. There are others, for example on communities and the length of time in construction and as well as when in operation. Orsted comes from the north and crosses Broadland, South Norfolk and south of Norwich to the national grid. North of Reepham is the cross point with the east-west Vattenfall (Vanguard and Boreas) and Orsted cabling routes. The Orsted route might interfere with some major development, for example it runs under the LDO Food Hub site. However the cabling route and substations are another example which is determined by central Government, and as such the impact is not evaluated by the GNLP sustainability appraisal. 

Water 8.11. Water resource consideration is the single greatest example of the above. We discuss this at some length in our Appendix 2, along with major road schemes. 

MAIN CONCLUSIONS AND RECOMMENDATIONS 

The Sustainability Baseline does not make the appropriate links to the Scoping Report of 21 March 2017, nor make use of  the wealth of information and data presented there.  The summary presented at 2.3 consists of little or nothing on the 15 sustainability themes, the current situation with little detail, but overall much on future scenarios which are speculative and not evidence based. With climate change there is a rewrite on issues and some speculation; that for employment and the economy taken or provided by the LEP; it is a summary of statistics of business sectors. Biodiversity loses any specific issues, and gives over more space to green infrastructure. As such it is not fit for purpose, and this may be why, while the baseline is mentioned at a few places in the text, it does not seem to be used in support of evaluation of reasonable policy alternatives and the assessment of environmental impacts. However these throughout do use the required sustainability appraisal framework as set out in the Scoping Report. 

The draft GNLP Objectives (4.5) are not objectives but longish straplines for the each of the six objectives. These were approved by the GNDP board at a 21 minute meeting on the 30 January 2017. At two lines each they can only over simplify, give inadequate information, or none at all, on some key matters.  This is particularly the case for number 6 the Environment; but that for the Economy is written so that there is no alternative policy other than the stated policy line. We consider that in fact there is a refinement which does offer a different and better objective. See our comment at 8.2.3. 

We conclude that these draft  GNLP objectives must be re-thought and re-written, cover all key aspects, be more explicit, and as such approach a half page length. They could also perhaps include some targets and indicators.  The draft is too brief and generalised to give even a high level view in the evaluation of the GNLP objectives against the sustainability objectives, as attempted at 4.6.3, and in turn negates the conclusions drawn on the six objectives; and in particular for the Environment, which concludes that this objective has a generally positive impact in relation to the SA objectives. The matrix evaluations and the commentary were also approved at the brief 30 January 2017 GNDP meeting. 

At chapter 7 we have Greater Norwich Local Plan: Options for Growth - The Strategy.  7.1.1 to 7.2.1 considers jobs, reasons for selecting the alternatives, and evaluating the significant effects. This is effectively done and we make comment and conclude in favour of JT2. On the Strategy for Homes at 7.3, 7.3.1 to 7.4. 4 we consider this to be a sound analysis on the options, and our comment on this argues for alternative 2; the GNLP housing requirement is equal to OAN, delivery buffer is approx. 20%, forecast windfall housing forms part of the 20% buffer. CPRE are supportive of the significant effects matrix, and the discussion of these and relative merits of alternatives.  The summary of effects is well balanced. 

Also in chapter 7 we have GNLP Strategy: How should Greater Norwich Grow?  - reasons for selecting the (distribution of development) alternatives. We first consider 7.5.3 to 7.5.19 and appendix B.  We note the housing allocation requirement set out in the table at 7.5.7. as representing alternative 2 as above, which includes a provision for windfall and has a total delivery buffer on 24%, which we accept other than that the delivery buffer of 24% could be reduced to closer to 20%, with a subsequent reduction in housing targets. In terms of the additional allocations needed in alternative strategies (table at 7.5.16) we would also accept the total of 7,200 houses, the baseline sub-total of 3,900 houses, and the additional allocations needed in alternative strategies at 3,300 houses, whilst bearing our previous point about a 20% rather than 24% buffer in mind. However on the latter we argue an increase at category C from 1,000 to 1,500; and a balancing reduction at D from 1,000 to 500. This on sustainability and service grounds to higher tiers, and concerns on the effectiveness of the village cluster concept. 

We have major concerns on the six alternative distributional strategies for the 3,300 houses needed on top of the baseline 3,900 houses, which is set out from 7.5.17 to 7.6.3. There are six options. These are Urban Concentration; Transport Corridors; Cambridge-Norwich Tech Corridor; Dispersal; Dispersal plus New Settlement: Dispersal plus Urban Growth.  Given that 3,300 houses is relatively small compared to the total housing requirement, the Options 2 and 3 might look to be not too different in practice for what we argue for on sustainability grounds, that is Option 1. We would however reject all three dispersal options, in particular option 4, as well as options 2 and 3 although these to a lesser extent than the three dispersal options.

Phasing. A problem with the consultation documentation including the interim sustainability appraisal is that phasing is not specifically offered as an option. It seems that this should be offered in the housing and distribution options sections as being the most logical places to address this, although it should be noted that many responders are not likely to mention phasing as it is not offered as an option. We feel this is a serious omission within the consultation.

It will take almost 24 years before the existing Plan's allocation of 35,665 houses is used up. In these circumstances we consider that there is no reason why new sites allocated in the GNLP should not be phased. They would then be available for development should building rates increase, but if house completions remain at existing rates, as appears likely, these sites could stay on a reserve list and valuable countryside would be protected, and other environmental impacts would be minimised.

We draw attention to the widely differing assessments in the assessment matrices showing the same set of factors in the Interim Sustainability Appraisal for the GNLP on page 42 and the table on page 80 of the 23 June 2017 GNDP Board Papers. While the most recent table confirms that overall urban concentration is a better option than dispersal, it is even clearer in the earlier version. The table on page 42 shows that urban concentration is better than dispersal in terms of: minimising air, noise and light pollution; improving well-being; reducing C02 emissions; mitigating the effects of climate change; protecting and enhancing biodiversity and green infrastructure; encouraging economic development covering a range of sectors and skill levels to improve employment opportunities for residents and maintaining and enhancing town centres; reducing the need to travel and promoting the use of sustainable transport modes. However, in terms of some of the other factors it seems that changes have been made to the table so that several options appear to be equal in terms of impacts, instead of showing what the earlier table demonstrated, which is that concentration was the best option and dispersal the least reasonable option. We do not understand the reasons for these changes in the assessments.

The Norwich Policy Area has served well for many years, with the rationale and benefits as set out a 7.4.1. CPRE Norfolk considers that it is essential to continue with a Norwich centred policy area. However we accept and support the case that, with an embedded Greater Norwich of three councils, that this might not apply for all policies, and that the retention of the NPA for calculating 5-year land supply is not a reasonable policy. We therefore support NCPA2. 

Chapter 8, Topic Policies, we disagree that the over-arching policy for the Economy is the only possible one. It rests on a flawed GNLP objective. This is indiscriminate growth, although it is acknowledged that some sectors will have a greater environmental impact than others. We propose a change in the objective, and with it an alternative policy: EC1 - Continue a wide-ranging approach to the economy, but prioritise the promotion of the high tech-high skill sectors and jobs. There is strong competition for these, and a good Norfolk environment supports investment and the recruitment and retention of staff. In social terms it supports the opportunities for young people. We discuss our response to 8.2.3, 8.2.4. 

It is very clear that there is an excess of employment land in the JCS. There should be selective criteria to overall reduce the amount allocated on the existing sites, and re-assigning to other uses, in particular housing. A Food Hub, with some heavy pruning on all types of 'bog-standard' activity, should be on the NRP site. 

We are supportive of the policy AH2 for the affordable housing provision threshold; an overall target of 27% of total housing provision, albeit requiring more on all qualifying sites, and phasing on larger sites. The ratio between affordable social rented housing and low-coat home ownership should be 80:20, and this tenure split should be applied to all sites.  Developers should provide a rigorous evidenced based viability case which can be monitored.  The most recent AMR data shows that the percentage of affordable housing is half the JCS target of 33%.  

The exception site policy should be as AH8; to allow (as does AH7) an 'open' and generalised policy of adjacent to development boundaries, would lead to sprawl, separation from basic services, and quite likely less total delivery. Developers should apply the SHMA bases evidence on meeting local need in making a site allocation. 

Our comments on other policy topics are brief as the document text is brief. There remains in chapter 8 the climate change and some Environment topics.  On climate change 8.6 the mantra is again to continue with the existing JCS policy. But note the implementation does not live up to policy, there is little monitoring data, and major road schemes completed, in progress, agreed in principle, or an aspirational county priority, are all taken through a separate process. These will show that the value for money is high, so is the cost benefit, and will not significantly add to existing pollution, or carbon dioxide emissions, and all else can be mitigated. As such environmental impacts are not part of this sustainability appraisal; see appendix 2 for our discussion, which also highlights in particular water resource, and the long-term sustainability implications which cannot be embraced here. 

The topic Environment at 8.8 is selective and brief.  On flooding it states that the GNLP steers new development away from flood risk areas, but does not say how this is done, and who is responsible. This is important to making land allocations in the first place. On nature conservation, this just deals with the impact on recreational use of SAC/SPA sites. Further the mitigation is limited to that through Green Infrastructure, which is inadequate. Very little is said on Landscape at 8.9, but we mention again a key failing throughout the document is the over-compartmentalisation of landscape and wildlife. The single most important example is to recognise river valleys are important not just as a landscape feature, but as a key part of the ecological network.  Biodiversity and landscape are intertwined; and where most closely so, both are water dependent, and includes the Broads of course as well as rivers. Water at 8.11 is also less than a full page.  

While the GNLP does consider water quality and efficiency, water resource is outside the remit. We discuss the environmental implications within the 2036 timescale of the Local Plan in our Appendix 2. In between Landscape and Water we have at 8.10 Energy. This states that the JCS policy will have to be changed on wind energy to avoid conflict with Government policy. We have noted that the land cabling route for the offshore wind farms will have impacts on both communities, and less well recognised, biodiversity; mainly from Orsted for GN, but also from Vattenfall .This can be added to our Appendix 2, as another topic which is determined by another separate process, and should be integrated with the GNLP sustainability appraisal process. 

Water Resource has interactions with the sustainability themes SA2 Climate Change, SA3 Biodiversity, SA4 Landscape, SA5 Housing and SA11 Economy.  Transport as regards major road schemes has interactions  with SA1 Air, noise and light pollution; SA2 Climate Change, SA3 Biodiversity, SA6 Historic Environment, SA14 Agricultural Land and SA15 Water. Clearly all the natural environment themes are liable for adverse impact from development, and there are cumulative effects. They are externalised in the sustainability appraisal process to several other separate and different routes to determination. There is a pressing need to review and make changes, so that the discussion of significant effects in the Local Plan sustainability appraisal can be more holistic and better protect our natural environment, our most basic and fundamental need.                      

APPENDIX 1. GREATER NORWICH DEVELOPMENT PARTNERSHIP-GREATER NORWICH LOCAL PLAN INTERACTION:  BACKGROUND AND MEETINGS 

BACKGROUND 

The roots of the growth agenda for Greater Norwich go back to the Region Plan in 2005. Just before the Inquiry, following some informal discussion across the county between the councils, the then Leader of Breckland Council 'broke ranks', and increased the district housing allocations from 11,000 dwellings to 15,000 dwellings. The reason given was the need to increase the provision of affordable housing, and 40% of all housing delivery would be affordable. Currently this councillor is Leader of the County Council. Also just before the Inquiry opened in September 2005, the county council withdrew the inclusion of a full northern  A 47 west to east dual carriageway road to mirror image that in place on the south,  which had in place protection from development along its route. The withdrawal was made because English Nature and the Environment Agency objected to the section that would cross the River Wensum SAC.  The full route was replaced by a three quarter route from Postwick in the east to Taverham in the west, called the Northern Norwich Distributer road (NDR). Following this the Greater Norwich councils accepted a higher level of housing but alongside made the case that the necessary infrastructure should be put in place. 

This history remains relevant to much of the current scene, but the economic growth trajectory greatly increased with the formation of the LEP, and its central connection with senior local politicians and the business community. There are some good reasons in principle in directing growth in selected high value parts of the economy, but we are now face less discriminating growth which would  severely impact on the environment. The GNDP Board drive the growth agenda. We therefore first discuss the GNDP meetings from January to June 2017, referred to in the quotes in the preface. In this context we thought it appropriate to discuss areas where national Government place major constraints on the sustainability process and the Local Plan in relation to the environment (see our Appendix 2). 

GREATER NORWICH DEVELOPMENT PARTNERSHIP- GREATER NORWICH LOCAL PLAN MEETINGS 

GNDP-Local Plan Meeting 30 January 2017 

This meeting had two main agenda items, reports with equal lengths of text, at eight pages.  These were Item 5 on the Communication Protocol, essentially a list of actions and references to communication sources to the public; and item 6 on the Greater Norwich Local Plan - Strapline, Vision and Objectives. The minutes, shown in the following 21 March meeting, confirmed that both reports were accepted as they stood. This 30 January meeting lasted 21 minutes.  

 Item 6 was a two page report requesting Members to agree that the draft Strapline, Vision and Objectives for the Greater Norwich Local Plan are suitable working versions to guide further plan development, as shown in appendix 1, two pages. This was supported by appendix 2, consisting of one page showing a matrix comparison of the proposed GNLP objectives and draft sustainability appraisal objectives; and three pages headed 'Conclusions on proposed GNLP objectives'. These appear in the draft Interim document unchanged with the GN LP Objectives at paragraph 4.5.1; the matrix comparison at 4.6.3 but now with the added key for re-numbered sustainability objectives; and the commentary/conclusions on relating the evaluation of the proposed GNLP objectives against the sustainability objectives is word for word as shown at paragraphs 4.6.4 to 4.6.9, pages 18-21.  

The strapline was 'Growing Stronger Communities Together', and the vision for Greater Norwich to 2036 was 'To grow vibrant, healthy communities supported by a strong economy and the delivery of homes, jobs, infrastructure and an enhanced environment'. The GNDP objectives are important as they are central to the Interim Sustainability Appraisal in terms of their intrinsic validity and how the Appraisal process is carried, and whether it follows the due process. We have: "The objectives for Greater Norwich to 2036 to promote sustainable development in a rapidly changing world are: 

Economy  To support and promote the growth of an enterprising, creative, broad based economy with high productivity and a skilled workforce. 

Communities  To grow vibrant, healthy communities giving people a high quality of life in well designed developments and good access to jobs, services and facilities. 

Homes  To enable delivery of high quality homes of the right size, mix and tenure to meet people's needs throughout their lives. 

Infrastructure  To promote the timely delivery of infrastructure to support existing communities and growth; and to improve connectivity to allow access to economic and social opportunities. 

Delivery  To promote the delivery of housing, jobs and infrastructure supported by intervention mechanisms where the market is unable to deliver. 

Environment  To protect and enhance the built and natural environment, make best use of natural resources, minimise contributors and adapt to climate change". NB The minutes state that at the request of a Member the last part of this objective was amended to say 'mitigate against and adapt to climate change' but that at 4.5 page 17 of the consultation document the original wording is retained. The Member may have a point, as all people are contributors, to a greater or lesser extent. 

The minutes also noted that the Objectives are a work in progress and would include more commentary as the Plan developed. The commentary/conclusions on each of the six GNDP objectives are quite brief but do have a note of realism in some respect. On both the Economy and Homes objectives for example we have: "Key conflicts result from the potential of new development to have a negative impact on issues such as air, noise and light pollution, reducing carbon emissions, protecting biodiversity, respecting landscape or heritage assets, loss of high quality agricultural land and impact on the water environment".  

On Infrastructure: "Where potential negative effects, or a negative component of mixed effects, are identified these are related to: the possibility that new infrastructure may have a physical impact on landscape or heritage assets; or where it is not planned to minimise impacts on air, noise or light pollution an CO2 emissions; or where opportunities for sustainable transport choices such as walking or cycling, which can support healthy lifestyles, are not addressed.  

The conclusion on the Environment however is overly sanguine".  It is considered that this objective has a generally positive impact in relation to the SA objectives". 

GNDP-Local Plan meetings 23rd March and 23rd June 2017.  

The next GNDP board meeting on the Local Plan was held on the 23rd March. The minutes (23rd June agenda) showed the meeting started at 9.30 am and finished at 4.06 pm. The main issues covered in the report were summaries of the current position in relation to a number of evidence studies currently underway; progress on the Greater Norwich Housing and Land Availability Assessment; and the next stages of the GNLP, including the implications of the Housing White Paper for plan-making. 

The general evidence required to underpin the GNLP was required to include assessments the scale of housing need across the housing market area; economic and employment growth and the future development of the local economy; transport infrastructure, including existing improvement plans and further requirements to support growth; key infrastructure requirements to support growth, including energy, water supply, waste water treatment, education and healthcare; environmental information, including landscape, ecology and air quality; the viability and deliverability of the Local Plan. 

We note that the minutes stated that "Advice to support work on Habitats Regulation Assessment, on internationally protected nature conservation sites, was being provided by the specialist consultancy the Landscape Partnership. Another specialist consultancy, Lepus, was providing advice on the Sustainability Appraisal (SA) process". The latter might explain the lack of connection in process between the Scoping Report issues on the 21st March 2017 and the draft Interim Sustainability Appraisal. We come to this below in our section on the draft sustainability baseline. In our view this sees a serious deviation not just from the Scoping Report but the overall sustainability appraisal process which needs to be corrected now. The chapter 2 on the Sustainability Baseline paragraphs 2.1 to 2.3.40, pages 4-10, is comprehensively wrong on several key sustainability themes. As this represents the draft baseline to be compared against alternative policy options it distorts the overall aim of this consultation.  

APPENDIX 2. NATIONAL GOVERNMENT CONSTRAINTS ON THE SUSTAINABILITY APPRAISAL PROCESS 

There are national factors which make it difficult to carry out an SA appraisal that does justice to the protection and enhancement of the natural environment, and put limitations on what can be done in producing a Local Plan. This crops up so frequently across the consultation that we mention them briefly now to avoid repetition throughout. These are housing requirements, water resource and transport. The housing situation is well known, but housing requirements are fixed through a national process without reference to other sustainability issues; but in general more housing means more people and more pressure on the natural environment, and mitigation is essentially a damage limitation process.  Many of the sustainability topics interlock with others, but the most fundamental need for people (and wildlife) is water resource.  

Water. By Government edict a water company must be in a position to have the water resource to supply to all new development as well as existing customers. This means that a 25 year plan needs to be put in place meet the forecast needs. So the current Anglian Water has a Water Resource Management Plan 2015-2040, and work is in progress to move to the WRMP 2020-2045. As far as a Local Plan is concerned, water resource is fixed and not formally considered , and certainly not in the longer term. The Local Plan is restricted to the Water Cycle, the quality of water, and flooding. The current WRMP would see the Norwich and Broadland Water Resource Zone require an intensive and expensive water efficiency drive to meet supply needs and environmental obligations. But by 2035 there would need to be in place other additional sources. The favoured option is North Sea water to be pumped to Norwich, undergo desalination (discharge pumped back to the North Sea) and then this 'raw' water be processed as now; and/or waste water treatment plants recycle their sewage and floodwater to a 'raw' water standard. The start point of all this is that the Norwich supply already suffers from major water stress and overall abstraction in terms of the environmental legislation. So the water company is faced both with an existing problem on water resource and meeting growth demands future growth demands. 

The water resource for the Norwich area is drawn mainly by surface abstraction from the River Wensum. In other parts of the county it primarily sourced by borehole into the aquifers, the water holding strata which feeds our rivers and wetlands as well as the water supply. The North Norfolk Coastal Resource Zone is also over-abstracted, and in this case abstraction by the water company has been reduced to a sustainable level. However, this Sustainability Reduction has to be compensated by finding a new source of water to meet existing usage.  This has been done by pumping water from the adjacent Fenland Resource Zone; and this in turn compensated with water drawn from further again inland, the North Rothamstead Water Resource Zone.  

In reviewing the current WRMP, the pumping of water from sources west to east across the country might find increasing favour over the desalination and waste water recycling options. But clearly all in the longer term are taking us into an increasingly unsustainable situation in environmental terms; and that is without taking account of ecological implications for our rivers and wetlands by introducing water of a different chemistry from that of the locality. However all the Local Plan can formally do is take water resource is a 'given', it is dealt with elsewhere, and not an issue to be integrated in the Local Plan sustainability appraisal process.  

There is also a similar situation with transport. The GNLP Sustainability Appraisal Framework is shown at Figure 84 of the Scoping Report of the 21 March 2017, pages 143-151. SA 15Water has an over-arching objective constrained to "Maintain and enhance water quality and ensure the most efficient use of water". Water resource links to SA2 Climate Change, SA3 Biodiversity, SA4 on Landscape, SA5 Housing, and SA11 Economy but this is missing in the Local Plan Sustainability Appraisal. Water resource should have some consideration in discussion of significant effects. 

Transport and access to services has an over-arching objective "Reduce the need to travel and promote the use of sustainable transport modes".  Major road schemes interact with SA 1 Air Quality and Noise, SA 2 Climate Change, SA 4 Landscape, SA 5 Housing, SA 11 Employment and the Economy, SA 13 Historic Environment and SA 15 Water. SA5 and 11 have  a 'positive' impact in the DfT strategy and funding policy supports major road schemes if they 'facilitate the delivery of housing'  (by unlocking the potential for development) and supporting economic growth. But again the resulting environmental impacts are not being taken into account as they should be in an integrated Local Plan SA.  

For example we take two quotes from this draft Interim SA.  At paragraph 8.3.3 we have: It is important to recognise that, whilst the GNLP may support strategic transport improvements, it is for the responsible bodies such as Highways England, Network Rail and Norfolk County Council as local Highway Authority to develop, promote and determine which strategic transport improvements, other than those directly related to a particular growth strategy, are necessary. And paragraph 8.3.5: The GNLP will need to identify any transport improvements that are necessary to support growth in the plan. And at 8.3.6: No overarching transport improvements that are a direct result of growth within the plan have currently been identified. In case that is not clear we also quote paragraph 8.3.5: The proposal at TR0 is simply to support strategic transport improvements which are, or will be, identified by the responsible Authority. The GNLP will not be proposing the transport improvements, such transport improvements will be promoted by the appropriate body and subject to separate SEA/SA as appropriate through a separate process. Whilst there will be benefits to ensuring a close relationship between the GNLP and transport infrastructure, in particular in regards to SA 11, the impact of this policy is not considered to constitute a significant positive impact on the baseline when considered against the "no plan" scenario. This conclusion has been reached as it can reasonably be expected that any strategic transport scheme that is agreed as part of the policies and investment programmes of the delivery bodies would likely go ahead irrespective of a broad supportive policy in the GNLP. Consequently the impact of this policy has been assessed as neutral. NB. Policy TR0: A policy broadly supporting and promoting strategic transport improvements.SA 11 is: To encourage economic development covering a range of sectors and skill levels to improve employment opportunities for residents and maintain and maintain and advance town centres.   

So we have for water resources and for transport major road schemes that these are externalised as regards the Local Plan. They will go ahead whether there is a Local Plan or not. Clearly the impact of these three areas is far from neutral, particularly in an area so heavily directed to a growth agenda. As such a sustainability appraisal for the GN area will result in a partial and limited assessment, and will far short on the environmental impacts. Major interlocking and cumulative interactions are 'lost'. Housing, water resource transport and other NSIPs are processed by another appropriate body, subjected to separate SEA/SA as appropriate through a separate body.  

We went through this process with the JCS and the NDR, and are set to go round the same loop with the Local Plan and the proposed Norwich Western Link Road. The case for the NWL road rests heavily on the Food Hub, itself part of an Enterprise Zone and as such not subject to the standard planning process.  The range of activities means it will be an HGV Hub, and the location such that it would support the NWL proposal. In addition, the dualling of the A47 from North Tuddenham to Easton will see a new junction location which would link to both the NWL and the Hub. We will continue to oppose the NWL as it would inflict major damage to the Wensum Valley landscape. 

On a wider note, in spite of the major constraints on the Local Plan process on environmental issues we continue to respond to this and other consultations. While the SA process takes a set of draft objectives and includes as an option a 'no plan' scenario' in our view a Local Plan with some major omissions remains considerably better than no plan at all. However CPRE Norfolk will continue to lobby for a better and fairer way to carry out the sustainability appraisal process that leads to the Environment Statement as a key document in the determination of the soundness of a Local Plan.       

Area 0244. I strongly object to the substantial loss of this protected woodland. This area is used by my family several times a week for health, fitness and wellbeing. This area along with 0133 D. E and F are also used by us and others for recreation. The proposal also acts as a barrier to access from Eaton Park to Earlham Park. The green areas stand as an important oasis within the proposed 0307 and 0331 scheme offering green suroundings to existing and new inhabitants alike. Norwich requires these areas for the cleansing of air and wellbeing of inhabitanats and visitors. The area may be essential to the health of the valley and waterway with concerns over runoff and pollution. I witness many forms of wild life from terrapins to otters, and this development would further impinge on the natural habitat, anaologous to the presence of the non native terrapins. As Norwich inevitably expands the valley and the watercourse should be protected.

Greater Norwich Local Plan Regulation 18 Consultation - March 2018
Representations on behalf of Mrs Katrina Kozersky-Gillham
1 We are responding to the Greater Norwich Local Plan Regulation 18 Consultation on behalf of Mrs Katrina Kozersky-Gillham. These representations make specific reference to an area of approximately 6.71 ha of agricultural land to the north of Farmland Road, Costessey ("the Site"). This Site is being promoted for residential development, and these representations refer to related policies and the development potential of this Site.
2 The comments below are specific comments on the consultation on the Interim Sustainability Appraisal. However, more general comments on this are made in connection with our comments on the Site Proposals Consultation Document (Appendix 1) and the Growth Options Consultation document (Appendix 2). Please refer to these appendices for our general comments.
3 The Sites position on the edge of Costessey provides a very sustainable location for new development, and it is available to come forward in the short term. There are strategic and local transport connections, plus easy access to nearby local amenities along with jobs, services, leisure and cultural facilities of the town centre.
4 The Interim Sustainability Appraisal sets out that a delivery buffer of at least 20% should be used to minimise the risks of under delivery. It is noted that this include windfall sites, but given the risks in terms of unpredictability with windfall development it should not be included as part of the delivery buffer. In particular, the Interim Sustainability Appraisal identifies that further research and fact finding is need to confirm the sources of windfall housing, and therefore it cannot be reliable upon at this stage.
5 We would propose an approach that combines all growth options would be most suitable and in accordance with national planning policy. This would recognise the need for development to be within sustainable locations, such as Costessey, whilst also supporting the sustainable and organic growth of rural settlements to prevent stagnation.
6 In light of this, we suggest the Site would be in accordance with all options, and should therefore be considered for future development as part of the next stage of the Local Plan.
7 We support that the Norwich Urban Area includes Costessey and this is identified as the first tier in the settlement hierarchy. This reflects the sustainability benefits of the area, proximity to Norwich and the accessibility to services and facilities. We agree with the growth considerations for this tier and consider that it is appropriate for a significant proportion of future housing allocations.
 
Appendix 1 - Site Proposals Consultation Document
 
Greater Norwich Local Plan Regulation 18 Consultation - March 2018
Representations on behalf of Mrs Katrina Kozersky-Gillham
1 We are responding to the Greater Norwich Local Plan Regulation 18 Consultation on behalf of Mrs Katrina Kozersky-Gillham. These representations make specific reference to an area of approximately 6.71 ha of agricultural land to the north of Farmland Road, Costessey ("the Site"). This Site is being promoted for residential development, and these representations refer to related policies and the development potential of this Site.
2 The comments below respond to the Site Proposals Consultation Document.
The Site Proposals Consultation Document
SITES QUESTION 2 - PLEASE COMMENT ON ANY OF THE SITES ALREADY SUBMITTED
3 As identified in 5.22 of the Site Proposals Consultation Document, Costessey is identified in the JCS as a major growth location. It benefits from facilities in Norwich and residents have access to a wide range of shops, services and leisure facilities, medical centre, and strategic employment area.
Land North of Farmland Road, Costessey (GNLP0238)
4 The Site is actively being promoted by the landowner for residential development. This Site is identified in the Housing and Economic Land Availability Assessment (HELAA) as site reference GNLP0238. We support the conclusion of the HELAA that the site is considered suitable for residential development, and we agree with the Site Proposals Consultation document that the site would be an extension of existing development in New Costessey and is largely unconstrained.
5 The Site is not a "valued landscape" within the meaning of paragraph 9 of the National Planning Policy Framework ("NPPF"). For the purposes of paragraph 47 of the NPPF, the Site is deliverable:
5.1 it is available now;
5.2 offers a suitable location for development now;
5.3 is achievable with a realistic prospect that housing will be delivered on the site within five years and in particular the Site is viable.
6 The Site directly adjoins the built up boundary of Costessey, with the Site boundaries to the south and east being formed by soft landscaping, with residential development beyond. Open fields lie to the west, with the River Tud and a densely vegetated area lying to the north. The Site slopes in a southerly direction towards the north of the Site, from a highest point of 26.5m above sea level down to 18.5m.
7 Immediately to the south of the Site lies a series of residential properties on Farmland Road, which date from the 1980s and comprise 1.5 - 2 storey properties. Farmland Road leads onto Grove Avenue, in turn connecting to Dereham Road and then wider areas of Costessey and beyond.
8 The Sites position on the edge of Costessey provides a very sustainable location for new development, and it is available to come forward in the short term. There are strategic and local transport connections, plus easy access to nearby local amenities along with jobs, services, leisure and cultural facilities of the town centre.
9 It is recognised the Site Proposals Consultation Document considers that the Site ''would be an extension of existing development in Costessey - it would need mitigation to deal with surface water flood issues and avoid harmful impact on the adjacent CWS, but otherwise is largely constrained.''
10 The Site has been subject to two recent applications (application references: 2015/2927 and 2017/0420) and the proposed indicative masterplan demonstrates that a scheme of up to 83 dwellings could be accommodated on the Site, including 27 affordable dwellings, and the creation of areas of public open space, sustainable drainage systems and associated infrastructure. Both applications were supported by all of the relevant and necessary documents, and both applications were reported to committee with planning officer's full support, with a recommendation for approval. Importantly, there were no statutory objections to the applications in respect of matters such as wildlife and ecology; flooding and drainage; design; contamination; landscaping; and highways. Detailed viability work, accepted by the Council, demonstrated that the proposals represent a deliverable development.
Deliverability
11 The Site is being actively promoted by the landowner. As illustrated by the recent planning applications it can be seen that the Site has no significant constraints, is in single ownership and is available to come forward now. It is considered that this should be given considerable weight when assessing this Site for allocation within the GNLP against other potential sites, particularly in Costessey.
Flooding and Surface Water Drainage
12 Details relating to surface water drainage were found to be acceptable as part of the previous applications. This is supported by a Flood Risk Assessment ("FRA"), and it provides details on the surface water drainage strategy for the Site. The proposed built development would be located outside Flood Zones 2 and 3, and the development would not increase flood risk. The FRA confirmed the ground conditions are suitable for infiltration drainage, and will not result in any adverse harm to protected species, the CWS, or the River Tud. This was been agreed with both the Environment Agency and the Lead Local Flood Authority as part of the recent applications.


Highways and Access
13 Access to the Site would be from Farmland Road. The Transport Statement for the Site to support the recent applications confirms that the impact of the proposed development of 83 dwellings on the surrounding highways network, will be negligible. Whilst recognising the steepness of the road, the Highway Authority ("NCC") confirmed that Farmland Road is suitable for this scale of development and that the local highway network is considered to be able to safely cater for the additional traffic generated by the proposed development.
Landscape and Design
14 A Landscape and Visual Impact Assessment (LVIA) has been completed for the Site to support the recent applications which demonstrates that that the level of harm will not be significant and demonstrable on the surrounding landscape and character area.
15 In respect of visual impact, it is considered that the indicative layout responds to the visual assessment, restricting built area to the G1 Easton Fringe Farmland Local Character Area and making strategic provision for planting that will, as it matures, reduce the visual effects further. In the opinion of the officer who professionally considered the proposals, the new visualisations confirm this conclusion.
16 Whilst the Site is currently a field in agricultural use, it abuts existing residential areas and as such the Council's Landscape Architect did not consider that the proposal is detrimental to the overall character of landscape character G1, especially in light of the demonstrated limited long-term visual effect.
17 In relation to the most recent application, the Council's Landscape Architect confirmed that in his professional judgement it cannot be demonstrated that there will be significant and demonstrable harm in either visual or landscape terms for development carried out in accordance with the layout and scheme as presented by the illustrative masterplan.
Ecology & Arboriculture
18 The proposed development of the Site has also been supported by ecological studies. The mitigation and enhancement measures proposed are considered necessary to mitigate any impact on ecology. This has been confirmed acceptable by the County ecologist in response to the recent applications.
Contamination
19 A contamination report was also completed for the Site as part of the recent applications and the Environment Agency, the Lead Local Flood Authority, and Council's Environmental Protection Officer were satisfied that any matters relating to contamination would be dealt with a condition.

Open Space and Green Infrastructure
20 Open space is proposed at the core of the new development. The proposed central green would connect to two internal green corridors which link to the north east and north west of the Site respectively. These internal landscape corridors will also be integrated with the SuDs system to create a distinctive and attractive landscape that links seamlessly with the new perimeter GI corridors and the wider landscape context of the River Tud valley. Provision is also included for a footpath through the CWS, with provision of a ramped footpath.
Other Matters
21 As identified in the HELAA there are no constraints in relation to utilities infrastructure, contamination or ground stability, no loss of open space and no impact on heritage assets.
22 CIL funds raised by the proposed development will contribute towards infrastructure needs in Costessey, including education, and in addition there will be other site specific matters which will be dealt with in S106 obligations.
23 Additional land to the north of the Site has been offered by the applicant to provide an additional area of recreation land, with the provision of two circular walks, and enhancements to the landscape. This formed part of a separate application (ref 2017/0420). It would be accessible to those near the Site and existing users of the CWS. This could provide network of paths both in the CWS and also to the north of the Site along the River Tud.


 
Appendix 2 - Growth Options Consultation Document

 
Greater Norwich Local Plan Regulation 18 Consultation - March 2018
Representations on behalf of Mrs Katrina Kozersky-Gillham
1 We are responding to the Greater Norwich Local Plan Regulation 18 Consultation on behalf of Mrs Katrina Kozersky-Gillham. These representations make specific reference to an area of approximately 6.71 ha of agricultural land to the north of Farmland Road, Costessey ("the Site"). This Site is being promoted for residential development, and these representations refer to related policies and the development potential of this Site.
2 The comments below respond to the Growth Options Consultation Document.
The Growth Options Consultation Document
DRAFT VISION AND OBJECTIVES
1. DO YOU AGREE WITH THE DRAFT VISION AND OBJECTIVES FOR THE PLAN BELOW?
3 We support that the vision includes the delivery of homes, and that this is then reflected in the relevant objectives. However, we would suggest this could be strengthened to ensure it promotes the delivery of housing to meet the identified need.
Delivering jobs, homes and infrastructure
2. DO YOU SUPPORT THE BROAD STRATEGIC APPROACH TO DELIVERING JOBS, HOMES AND INFRASTRUCTURE SET OUT IN PARAGRAPHS 4.1 TO 4.7?
4 We support that 'the strategy will deliver the housing that is needed', and that this will go a long way to support housing growth in all towns and villages with a range of services. It is noted housing figures are discussed in para 4.4 and these are discussed in more detail below.
5 We support the fact that the plan seeks to include additional sites to provide a buffer to maximise the potential to deliver the housing to tackle the housing shortage and to support economic growth.
Housing Need
4. DO YOU AGREE THAT THE OAN FOR 2017-2036 IS AROUND 39,000 HOMES?
6 In paragraph 4.15 it is noted that reference is made to the wrong paragraph of the National Planning Policy Framework ("NPPF") at footnote 18 - it should be paragraph 14. We note that paragraph 47 of the NPPF requires, inter alia, for local planning authorities to boost housing and use their evidence base to ensure that their Local Plans meet the full, objectively assessed needs for market and affordable housing in the housing market area. In short the OAN should be used to identify housing need and, therefore, the number of sites which should be identified for housing to meet that need.
7 The 39,000 homes figure is established using the Government's proposed standardised methodology, which suggests the combined OAN for all of the Greater Norwich authorities is 2,052 homes per annum. The principle of using the Government's standardised methodology figure is welcomed. However we would question whether the proposed OAN is 'sound' in the first instance and we suggest that further clarification is required. In particular, the draft revised NPPF and NPPG have now been published, and it is clear that the need figure generated by the standard method should be considered as the minimum starting point in establishing a need figure for the purposes of the plan production. The OAN figure needs to be subject to careful scrutiny and consultation before it can be used as the basis for decisions on allocations and, indeed, in assessing whether five-year housing land supply requirements are being met.
8 Reference is made in the Growth Options document para 4.17 that the standard methodology can be rebased to the current monitoring year to give an OAN from 2017 to 2036 of 38,988 dwellings. It is not entirely clear why it is considered appropriate by the local planning authorities to rebase the OAN to 2017 given the extent of persistent under delivery in the years that have preceded that against figures in the JCS used to support housing allocations. In any event, the Government figure used is from 2016, which suggests an additional 2,052 dwellings is necessary to account for 2016-2017. Therefore increasing the OAN to 41,040 homes over the plan period as a minimum. Further adjustments may also be required to take account of any updated published affordability ratios or updated household projections. Therefore refinement may result a higher figure which would be the updated starting point in establishing a future need figure for the plan.
5. DO YOU AGREE THAT THE PLAN SHOULD PROVIDE FOR A 10% DELIVERY BUFFER AND ALLOCATE ADDITIONAL SITES FOR AROUND 7,200 HOMES?
9 It is supported that that the plan will seek to over-allocate against whatever the appropriate OAN is to maximise the potential to deliver the housing needed to tackle the housing shortage and to support economic growth. However, further clarification is required on the identified buffer and additional sites for the suggested 7,200 homes.
10 The Growth Options document para 4.16 outlines that the SHMA 2017 identifies that the OAN for Greater Norwich from 2015 to 2036 is 39,486 homes (1,880 per annum) excluding the City Deal Aspirations. Para 4.19 refers to the SHMA calculation of how many homes would be required to support enhanced growth in order to meet the 'City Deal'. It then continues that a 'simple recalculation of the SHMA assessment to rebase to 2017 suggests that around 40,700 dwellings would be needed to support potential jobs growth (forecast growth plus City Deal aspirations)'.
11 In principle, it is supported that the GNLP should allocate sufficient opportunities to support the City Deal and ensure economic growth can be met. This is also recognised by the draft NPPG that 'where additional growth...will occur over the plan period, an appropriate uplift may be applied to produce a higher figure that reflects that anticipated growth'. Figure 96 of the SHMA outlines 44,714 dwellings in response to the City Deal between 2015-2036. The figure in para 4.19 appears to omit the period from 2015-2017, with a shortfall of 4,014 homes and it is not entirely clear why this has been done. It is therefore unclear if this has sought to take into account delivery over these years.
12 The SHMA figures would suggest an additional 3,674 homes would be required to meet the City Deal aspirations, against the potential higher standard methodology figure. As a result the 10% buffer applied to the suggested 39,000 dwellings OAN figure would therefore not be sufficient to meet the City Deal aspirations. Applying the 10% buffer to the suggested 41,040 figure above, raises the plan provision to 45,144 homes which would be slightly above the SHMA City Deal figure. If the SHMA, as published is not sound as an evidence base, the figure could be higher in any event.
13 As such, there is concern that 10% is not sufficient to tackle the housing shortage, as this buffer would only seek to meet the City Deal aspirations. Given the shortfall in housing delivery in previous years it is considered an increased buffer is required to ensure sufficient housing sites are delivered over the plan period and meet the City Deal aspirations.
14 The Interim Sustainability Appraisal sets out that a delivery buffer of at least 20% should be used to minimise the risks of under delivery. It is noted that this include windfall sites, but given the risks in terms of unpredictability with windfall development it should not be included as part of the delivery buffer. In particular, the Interim Sustainability Appraisal identifies that further research and fact finding is need to confirm the sources of windfall housing, and therefore it cannot be reliable upon at this stage.
6. DO YOU AGREE THAT WINDFALL DEVELOPMENT SHOULD BE IN ADDITION TO THE 7,200 HOMES?
15 Yes, we consider that windfall development should be in addition to the 7,200 homes (or any subsequent updated figure). However for the reasons given above it should be in addition to the overall buffer of 20%. We also point out that there does not appear at this stage to have been any detailed analysis of the source of windfall housing. These are, by definition, unallocated sites and although paragraph 4.23 states that windfall development often takes place on small scale unallocated sites or as higher than expected numbers on commitments, there is no evidence to support this assertion. We would add that a number of sites have come forward on unallocated sites because of the inability of the local planning authority to demonstrate five-year housing land supply. We assume that these too will have contributed to windfall.
16 As identified in para 4.23 the actual sites that come forward and the precise scale of delivery is unpredictable and therefore would not provide any certainty in terms of the potential to maximise housing delivery.
8. IS THERE ANY EVIDENCE THAT THE EXISTING HOUSING COMMITMENT WILL NOT BE DELIVERED BY 2036?
17 We do not agree with the approach set out in para 4.40 that 'assumes that existing housing commitments can be delivered'. Given the current lack of five year housing land supply, it is clear the housing commitments are not coming forward as expected, particularly in the NPA. This is no evidence to suggest this would be any different for the existing housing commitments moving forward.
HOUSING GROWTH OPTIONS
9. WHICH ALTERNATIVE OR ALTERNATIVES DO YOU FAVOUR?
18 We would object to adopting any single one of the Options as currently set out. We agree that fringe locations should be supported as a broad location for growth, and in particular that Costessey is included in all Options as part of the western fringe to Norwich.
11. ARE THERE ANY OTHER STRATEGIC GROWTH OPTIONS THAT SHOULD BE CONSIDERED?
19 We would propose an approach that combines all growth options would be most suitable and in accordance with national planning policy. This would recognise the need for development to be within sustainable locations, such as Costessey, whilst also supporting the sustainable and organic growth of rural settlements to prevent stagnation.
20 In light of this, we suggest the Site would be in accordance with all options, and should therefore be considered for future development as part of the next stage of the Local Plan.
GREEN BELT
21 13. DO YOU SUPPORT THE ESTABLISHMENT OF A GREEN BELT? IF YOU DO, WHAT ARE THE RELEVANT "EXCEPTIONAL CIRCUMSTANCES", WHICH AREAS SHOULD BE INCLUDED AND WHICH AREAS SHOULD BE IDENTIFIED FOR GROWTH UP TO AND BEYOND 2036?
22 We do not support the establishment of a Green Belt. We strongly agree with para 4.73 that there is no evidence to meet the 'exceptional circumstances' required by the NPPF to justify the establishment of a Green Belt for Norwich.
Settlement Hierarchy
23. DO YOU AGREE WITH THE APPROACH TO THE TOP THREE TIERS OF THE HIERARCHY?
23 We support that the Norwich Urban Area includes Costessey and this is identified as the first tier in the settlement hierarchy. This reflects the sustainability benefits of the area, proximity to Norwich and the accessibility to services and facilities. We agree with the growth considerations for this tier and consider that it is appropriate for a significant proportion of future housing allocations.
The influence of the Norwich Urban Area
26. DO YOU SUPPORT A NORWICH CENTRED POLICY AREA AND, IF SO, WHY AND ON WHAT BOUNDARIES?
24 It is clear from the review of the SHMA that there is not a clear single HMA that encompasses Broadland, Norwich and South Norfolk boundaries only. Breckland and North Norfolk are within the Functional Housing Market Area. Furthermore, the long established NPA area serves an important purpose to focus development in and around the urban area, and promoting the economic strength of Norwich and its surrounding area. The Core Area in the SHMA is similar to the NPA, and is identified as having the strongest connections to the Norwich Urban Area. There has been no consideration of any implications for the removal of NPA. Therefore it is considered important to retain a Norwich centred policy area to direct growth appropriately.
25 It is not considered appropriate at this early stage to determine the retention of the NPA or a similar area for measuring five-year land supply is unreasonable. The draft revised NPPF and draft revised PPG have only recently published and the final versions once published will need to be taken into account as part of future stages of the GNLP. Further consideration of the new NPPF and NPPG would be required in order to assess the suggested approach in relation to the future of the Norwich centred policy area and the five-year housing land supply.
Shortfall in Housing Land Supply
65. WHICH OPTION DO YOU SUPPORT?
26 Further consideration is required to address any shortfall in housing land supply. Given the current lack of five-year housing land supply (accepted and acknowledged in paragraph 1.4 of the Executive Summary to the latest Annual Monitoring Review), we have suggested the proposed buffer to the overall housing requirement should be increased to ensure sufficient sites come forward. Every effort should be made at this point to identify sufficient and deliverable sites, and to help them come forward. This should identify additional sites for the short term, and also build in potential for reserve sites.
27 The draft NPPF and NPPG include a Housing Delivery Test, and also the requirement to prepare an action plan to reflect challenges and identify actions to address under-delivery against the housing requirement. This should be reflected in the GNLP.

We acknowledge that this is an interim sustainability appraisal, and note that presumably more detailed appraisal of policy options will be carried out prior to the Regulation 19 consultation.

1. Appraisal of objectives
It is difficult to carry out a meaningful appraisal of such broad objectives. However, one point we wish to make in relation to the economy objective is that "an enterprising, creative, broad based economy with high productivity and a skilled workforce" is not necessarily incompatible with reducing carbon emissions and adapting to climate change. The transition to a zero-carbon society actually brings many opportunities for skilled and useful work in renewable energy, construction, repair and recycling, etc. If steps are taken to promote this 'green economy' in Greater Norwich, economic prosperity will actually help with regard to SA2. It is true, however, that the current economy, based on ever-greater consumption of resources, is harmful to objectives on climate change.
On the 'homes' objective, there should be a mention of how good design for energy and water efficiency can minimise the negative impact on reducing carbon emissions and preserving water supply.
A theme running through this section is the self-contradictory assertion that several of the objectives will have a negative impact on conservation, air quality, reducing emissions, and water supply, but a positive impact on 'quality of life' and 'deprivation'. Any meaningful measure of quality of life presumably includes breathable air and sufficient potable water. The way these outcomes are weighed up against each other perpetuates an artificial separation of economic, social and environmental issues - how can you have social justice or economic prosperity if your air and water are poisoned and your home under threat from extreme weather?

2. Assumptions
The interim SA lists several assumptions that have been made. We understand that a number of factors make a certain degree of assumption necessary. However, there is a crucial difference between an assumption based on available evidence (where the evidence is used to come up with a 'best guess' in the absence of certainty) and an unevidenced assumption based on received wisdom or someone's opinion.
To give three significant examples: firstly, it is stated that "within the limits of this assessment it is assumed that a higher release of land for housing would result in high delivery rates and overall build out levels." However, no evidence is cited for this assumption, despite the previous sentence having essentially acknowledged that it is in fact likely to be false. For an issue of such central importance to the plan, evidence should be sought based on current unbuilt planning permissions in Greater Norwich, past allocation levels and build-out rates, and comparisons from elsewhere in the country. As it is, the assumption that 'more allocations = more housing' is used to prop up arguments for a high delivery buffer, which would be likely to result in significant unnecessary development of land with valuable agricultural and/or biodiversity value (which developers will tend to favour over more complicated brownfield sites).
Secondly, the SA goes on to say that "A wide dispersal and mixture of development sites is assumed to provide more choice and competition in the housing market, which has benefit in terms of housing delivery." We have two major concerns about this claim. One, there is again no evidence for an assumption which is subsequently used to skew the SA heavily towards the dispersal options (which are unacceptable according to almost all the SA criteria). Two, the phrase "choice and competition in the market" is used repeatedly in the consultation document. However, here it is "the housing market", while in several instances elsewhere it is "the market for land". These are two different things. "Choice and competition in the housing market" would seem to refer to choice for homebuyers and competition among builders/sellers for their custom. "Choice and competition in the market for land", on the other hand, is an extremely woolly phrase. Who is competing with whom for what? Choice and competition in the marketplace are generally two sides of the same coin: if there are lots of cake stalls at the market, I as a purchaser have choice, while the cake vendors have competition. In the case of the 'market for land', whether the landowners have competition and the developers have choice or vice versa, it is not at all clear why this 'competition' is increased by the choice of dispersed rural sites over urban ones, nor how it will speed up housing delivery, which is in any case quite another matter from simply obtaining land or planning permission.
Finally, it is also "assumed that larger sites [...] are less likely to be able to provide higher proportions of affordable housing" - again with no supporting evidence (and certainly no evidence that lack of affordable housing is due to higher site costs, rather than simply a greater willingness on the part of large developers to hire consultants to write viability assessments which allow them to escape their affordable housing obligations).

3. Appraisal of growth distribution options
The appraisal gives a useful overview of the impacts of different options. There is less differentiation than might at first be expected, but we appreciate that at this stage, it may not yet be possible to make finer distinctions between some of the options. However, we take issue with the conclusion ('Summary of significant effects') and the way it has been reached. Looking at the colour-coded table and the detailed commentary, the most obvious conclusion to be drawn is that options 4, 5 and 6 perform significantly worse. Yet the concluding remarks open with "Options 1, 2 and 3 may be significantly harder to deliver" - skating over everything the SA has said, and choosing instead to comment on something that it is not best placed to evaluate. 'Delivery' is not a criterion of the SA - indeed, delivery of a bad plan could hardly be said to be a sustainable outcome.
7.6.2 acknowledges that options 1, 2 and 3 outperform the dispersal options on "objectives that seek to improve air quality, reduce the impact of traffic, address climate change issues, increase active travel and support economic development". Once again, the conclusion appears overwhelmingly obvious. Yet the overall conclusion reached is a total non-sequitur: "in sustainability terms the choice between alternatives [...] appears finely balanced, with no alternative clearly better than another". This blatantly flies in the face of everything the SA says - it is not a legitimate conclusion in any sense. This use of the vague and unevidenced claim about 'delivery' (which apparently weighs equally with every single SA criterion put together) cannot go unchallenged. If the next iteration of the SA remains at this shockingly poor level of 'analysis', it risks rendering the plan unsound.

4. Appraisal of policy options
We consider the logic to be flawed in the appraisal of option SH2. 7.13.1 states that "if villages are clustered in such a way that higher growth is only allocated where the levels of accessibility to services is good then the impact of this approach could also be positive in respect of SA1, SA2, SA6, SA7, SA8, and SA12." But ensuring "higher growth is only allocated where the levels of accessibility to services is good" is the purpose of the existing settlement hierarchy. Merging several categories, whatever the detail of how it is done, unavoidably undermines this - the purpose of option SH2 is precisely to allow growth to be allocated further from services. "It's too early to tell" is an unacceptable cop-out position for the SA to take on a proposal that would clearly have a significant negative impact on several of the plan objectives and SA criteria.
The section on policy options underlines how unsatisfactory it is to have only one option on major issues such as climate change and energy - they can only be appraised against a 'no plan' scenario, which is an extremely low bar. The SA ought to be evaluating a range of policy options so that well-informed decisions can be made.

5. Monitoring
Please see our response to Q. 50 and Q. 64 of the Growth Options consultation.


N.B. The GNLP objective on climate change has changed to 'mitigate against' rather than 'minimise contributors to' - in the SA (4.5), this has not been updated.

Natural England is satisfied that the SA objectives, assessment methodology and framework generally accord with the requirements of the Planning and Compulsory Purchase Act 2004 and the Strategic Environmental Assessment Regulations.

HRA
The future conclusions and recommendations of the Habitats Regulations Assessment (HRA) will need to be incorporated into later revisions of the Sustainability Appraisal (SA) report, and be reflected in the allocations and policies of the Local Plan.

Water Cycle Study
Natural England advises that a Water Cycle Study should be completed as soon as possible to provide the evidence required to inform the SA and enable sound judgements to be made regarding which allocations are sustainable and can be taken forward. The SA will not be able to rely alone on the emerging development management policies to mitigate the potential adverse effects of proposals on the natural environment, including designated sites. How the issues of water abstraction and waste water management and treatment capacity will be dealt with through the Plan will be informed by the findings of the Water Cycle Study. Any mitigation measures will need to be secured through relevant allocation policies.

Recreational Disturbance
The issue of additional recreational pressure associated with proposed growth, and measures needed to address this, should be addressed through the SA, having regard to the objectives of the strategic in accordance with GI policies and the Strategic GI Network for Greater Norwich map. The findings of the SA, relating to GI, should be referenced in policies. Mitigation measures identified in the SA should be secured through the relevant site allocation policies together with a clear delivery/funding mechanism.

With regard to GI, we question why the Reasonable Alternative NC3 has not been included in the Growth Options consultation under Q53 as it has the highest positive score of the three options. NC3 states:

NC3 - Broadly reproduce the current JCS Policy 1 elements as they relate to green infrastructure, updating the baseline information (such as the GI Map), with each allocated site setting out the details of any specific mitigation measures/improvements within its allocation policy

We support this approach particularly as it would set out specific mitigation measures for each allocated site where appropriate.

Best and Most Versatile Land
Where no site-specific Agricultural Land Classification (ALC) survey information exists, the Local Plan should specify the need for those proposing sites to undertake a suitable site-specific ALC survey to inform the assessment process. We expect that the site-specific ALC survey data is used to consider the impact on soils through the SA to fully explore the justification for allocating best and most versatile (BMV) land, and ultimately to inform site specification and masterplans. Currently, there is no real consideration of this issue in the Regulation 18 consultation documents.

Comments on Interim Sustainability Appraisal
The historic environment should be considered as part of the sustainability appraisal process. We recommend that these comments should be read alongside our Advice Note 8, available here: https://historicengland.org.uk/images-books/publications/sustainability-appraisal-and-strategic-environmental-assessment-advice-note-8/
Key Sustainability Issues
We would suggest that the starting point for considering Key Sustainability Issues for the Historic Environment should include:
 Conserving and enhancing designated and non-designated heritage assets and the contribution made by their settings
 Heritage assets at risk from neglect, decay, or development pressures;
 Areas where there is likely to be further significant loss or erosion of landscape/seascape/townscape character or quality, or where development has had or is likely to have significant impact (direct and or indirect) upon the historic environment and/or people's enjoyment of it
 Traffic congestion, air quality, noise pollution and other problems affecting the historic environment
We would expect to see consideration of opportunities. It is considered that the historic environment can make a significant contribution to the success of development and there may be opportunities for the enhancement of the historic environment which comes from sustainable development proposals. It is considered that the Sustainability Appraisal should highlight these opportunities. Examples of the sorts of opportunities that can be used can be found in our guidance notes in the links above.
We request that the sustainability issues table at the start of section 3 is amended to replace the term built heritage with the historic environment. The issues set out in this table are appropriate and we are pleased to see reference to the effects of more intangible elements such as pollution, traffic, etc. on the historic environment. We recommend however that heritage at risk is also listed as an issue here.
As outlined earlier in this letter we do not agree with the GNLP objectives which are replicated in section 4 of the Interim SA as they do not contain any reference to the need for the conservation and enhancement of the historic environment as required by the NPPF. Given that these objectives have been used to evaluate the SA objectives we necessarily have fundamental concerns with the SA findings which consider the objective to have a generally positive impact.
We are however pleased to see the inclusion of SA Objective SA13, this objective is appropriate and has been used to assess the potential effects of policies within the GNLP. SA13 makes appropriate reference to setting and the wider historic environment.
We note that a number of the policies would result in significant negative impacts upon the SA13 baseline. We therefore expect to see the inclusion of criterion which address the negative effects of the options to be taken forward.
Method for Generation of Alternatives
The historic environment should be a factor when considering a method for the generation of alternative proposals. The impact of proposals on the significance of heritage assets should be taken into consideration at an early stage. In terms of sites, this should be based on more than just measuring the proximity of a potential allocation to heritage assets. Impacts on significance are not just based on distance or visual impacts, and assessment requires a careful judgment based on site visits and the available evidence base.
Conclusion
In preparation of the forthcoming Local Plan we encourage you to draw on the knowledge of local conservation officers, the county archaeologist and local heritage groups.
Please note that absence of a comment on an allocation or document in this letter does not mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic environment or is devoid of historic environment issues. Where there are various options proposed for a settlement, identification of heritage issues for a particular allocation does not automatically correspond to the support for inclusion of the alternative sites, given we have not been able to assess all of the sites.
Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.

Section 2.
You state that new housing and economic growth need to be considered together but you have not done this for the JT2 Alternative, a "Credible " Alternative to the wildly aspirational JT1. In fact JT1 is taken as a given in the SHMA doc and JT2 is not tested. JT2 is unlikely to have JT1s "significant negative effects" on the SA. Consequently all the test options are based on JT1.(7.3.21).
I object to the denigration of JT2 as "business as usual" as it exceeds the current strong growth trends.
Further baseline comment is that you require to deduct windfall from your baseline and not ignore it or use it as additional delivery buffer- see section 7, 7.3.4.

Section 6.
Page 24. Higher release does not equal higher delivery as national builders and speculators will simply land bank to maintain prices.
Strategic transport improvements require to be assessed in the SA due to cumulative impact, particularly the NWL that is dependent on west/north west GNLP growth model - See WSP stakeholder Consultation on behalf of NCC.

Section 7.
7.3.4. Windfall housing requires to form part of the baseline calculation as 5,600 is a "reliable figure". Even using JT1 inspired OAN the arithmetic should be 39,486-5,600 = 33,886 (30,658 for 2017-36).
7.39. Contrary to what you say, there is justification for lower the OAN.
A) use the JT2 input in SHMA. B) there are constraints (7.3.8) on JT1 based OAN ie the significant negative effects in the SA. Otherwise why produce an SA.
7,3.13. NPPF (para 4) can also mean that you adjust downwardly should the gung ho aspirational development of JT1 prove wide of the mark, very likely due to an automation transition period concurrent with the Plan period. You do not consider this factor. A hand on tiller approach based on JT2 is better as it is easier to step up rather than down.

Section 8.
8.3.4. The overarching transport policy is not neutral as A) you ignore cumulative impact, B) you have not quatified carbon abatement costs, C) virtual shelving of all sustainable transport measures in the NDR DCO and NATS. And D) you are actually encouraging greater car reliance (8.3.7).
8.8 CC1 is unfit as it is not based on up to date methodology, does not take account of "the significant and ongoing carbon emissions" from the NDR ( SOS for Transport) and uses weak language - mitigate, proportionate, if practicable etc.
Flooding. The lead flood authority's guidelines were flouted on the food hub LDO treated as reserved matter and not concurrent.
Green infrastructure. Please insert" a safe cycle and walking network, including disabled facilities will be provided between all villages, residential areas and places of work.
Landscape. Norfolk's beauty is understated therefore susceptible to 'just another field' mentality.
Water. We are under severe water stress yet this will be exacerbated possibly to the point of crisis by pursuing the wildly aspirational JT1 while ignoring the credible JT2 Alternative.
Communities. The roads budget will swallow any Cil money, see the overspend on the NDR and the £50million and rising per mile NWL. Thus your growth model will have significant negative effect as there will be no money for community infrastructure, big Society projects or schools improvement.
Monitoring.
There is a lack of historical perspective. There should be a preface on past promises eg on NATS and NDR where £50million should have been spent/allocated for sustainable transport, yet only £1.5 million spent. A review is currently taking place by NCC in breach of the DCO.

For full representation, please refer to the attached documents.