Object
Publication
Representation ID: 24490
Received: 22/03/2021
Respondent: Norwich Green Party
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
We comment on clause 76 as background to our response on Transport Policy 4.
The statement about relatively poor infrastructure limiting growth stands in stark contradiction to the Economy Profile which describes Greater Norwich as a world leader in plant and climate change research, a nationally significant retail centre, a centre for financial services and a national contributor to the UK’s food supply and part of the wider area’s world leader status in off-shore wind energy.
It is the case that Greater Norwich has historically poor public transport and local rail infrastructure relative to other cities. This acts as a major constraint in trying to encourage modal shift to sustainable modes of transport and is a barrier for the significant percentage of households without private transport in endeavouring to access employment, education and other essential services.
We disagree with the frequent and persistent claim that Norfolk is a poor relation in terms of the road network compared to the south-east and London. This is rolled out as ‘evidence’ that the local road network is holding back development and that further dualling of Norfolk’s roads is essential for growth. This attitude has skewed the County’s priorities and spending. (in 2016 Norfolk County Council voted spending on the Norwich Western Link, the 3rd Great Yarmouth River Crossing and the Long Stratton Bypass as the County Council’s top spending priority for the future) and its transport agenda in favour of road building and accommodating travel by private car.
A large body of academic research has challenged assumptions about the effects of new road infrastructure and economic growth (for example ); on how we cannot build our way out of congestion and on how optimistic traffic predictions can lead result in building surplus road space.
Road improvements add vehicle capacity and speed up journey times, encouraging people to live further from their workplaces; this in turn leads to more dispersed development, increased reliance on car use, more congestion and pollution and more demands for improved roads.
Nonetheless, Norfolk County Council has demanded much larger road schemes than necessary for addressing localised problems or for serving new development. For example, the A11/A47 Thickthorn Junction is a major project which Highways England acknowledges will increase carbon emissions. The Agency originally proposed a small scheme with the objective of assisting buses to negotiate the A11/A47 Thickthorn roundabout and serve new housing growth along the A11 corridor. Norfolk County Council lobbied for a major junction improvement with the aim of increasing road capacity and serving housing growth. To address the likelihood of an enlarged junction attracting single occupant car commuters travelling short distances, the Council proposes expanding Thickthorn park and ride. This mirrors the story at A47 Postwick Junction, where the County Council doubled the capacity of Postwick Park and Ride in 2014 on the back of Postwick Hub and ended up leasing unfilled spaces to Aviva at the adjacent Broadland Business Park.
The County Council frequently cites the rural nature of Norfolk and reliance on the private car as a reason for road improvements. This argument is over-stated. A majority of the Norfolk population lives in Norwich, Great Yarmouth, King’s Lynn and 21 market towns where there is considerable scope for people switching to active travel and public transport. Most journeys in the UK are short. In 2017, 67% of journeys were under five miles; a further 15% were between five and ten miles, whilst journeys of over 10 miles made up less than a fifth of all trips. Over 60% of journeys of between one to two miles are made by car or van.
An example of Norfolk’s reliance on car use is Wymondham along the A11 corridor, nine miles from Norwich with direct rail links to Norwich and Cambridge. Census data (2011) shows that 22.1% of residents in Wymondham travel less than 2km (walking distance) to work and 30.2% travel less than 5km (cycling distance) to work. On the other hand, 71.8% of Wymondham residents (2011 Census), drive to work, mainly in Norwich. A conclusion of the market towns study is that travel pattern data shows the huge potential for a shift to active modes of transport for commuting.
For further information see attachment.
The statement, ‘Historically relatively poor strategic infrastructure links limited growth in the area’ is only partially correct and should read:
“Whilst the strategic and local road network is largely in place, poor public transport and rail infrastructure limit accessibility to employment and essential services and discourage modal shift to sustainable transport modes”.
Summary
We consider the GNLP to be unsound:
- Not positively prepared
- Not justified
- Not effective
- Not consistent with the NPPF
The GNLP Reg 19 would increase carbon emissions, contrary to the national legal target of net zero by 2050. The policy framework on climate change and local plans is addressed in the Centre for Sustainable Energy paper. Although climate change has been strengthened in the GNLP by the inclusion of a new climate change statement, it has been bolted onto to a previously prepared growth strategy and set of policies which are inconsistent with the statement and the evidence base on climate change. The GNDP is aware of this deficiency because they have agreed to review the Local Plan on climate change following its adoption.
The GNLP was not ready for the Regulation 19 stage. GNDP members had agreed to commission further work and undertake a Regulation 18C six week focussed consultation, but following the Planning White paper, they decided to proceed immediately to Regulation 19.
In our view, the Plan should not be accepted as sound but returned to the GNDP for further work to ensure soundness.
There are a number of matters which we consider to be unsound because they are
incompatible with the duty to proactively contribute to the mitigation of, and adaptation to, climate change under section 19 (1A) of the Planning and Compulsory Purchase Act 2004 which requires Local Plans to include:
“policies designed to secure that the development and use of land in the local planning authority’s area contribute to the mitigation of, and adaptation to, climate change”
The matters include:
- Absence of an overall carbon budget for Greater Norwich to 2050 consistent with the Climate Change Act 2008, supported by a strategy and policies in line with the carbon budget trajectory.
- High housing number which will increase development pressures on greenfield sites;
- Growth that includes dispersal of development to small villages which lack services and the possibility of new garden city settlements in open countryside distant from railheads (Thorpe Honingham, Hethel and Silfield).
- Sub-optimal energy efficient standards and renewable renewable energy generation
- Lack of attention to retrofitting of historic development.
- A transport strategy which would increase carbon emissions by caterimng for traffic growth and modest modal shift to bus, walking and cycling.
- Inclusion of a Norwich Western Link.
- Support for improvements to strategic highways.
Several of these issues are addressed in the Reg 19 response by the Centre for Sustainable Energy which was commissioned by Norwich Green Party (on sustainable communities, zero carbon development, sustainable transport, renewable heating, renewable energy generation and retrofitting of traditional and historic buildings).
The CSE paper forms part of our representation on Regulation 19.
We also endorse responses submitted by other parties who share the same concerns on a range of matters: CPRE, Norfolk Wildlife Trust, Wensum Valley Alliance, Dr Andrew Boswell and Client Earth.
They cover soundness matters at considerable length:
- Climate change
- Housing numbers
- Growth Strategy
- Green Wedges
- Green Infrastructure
Norwich Green Party Group’s representation mainly covers Transport Policy 4 which we consider to be unsound. We also make comments on a number of individual development sites: East Norwich, Anglia Square and on the smaller King Street Stores site.
The changes to the Plan that we would like to see are those we have set out in our previous representations on Regulation 18. They include:
- An overall carbon budget for Greater Norwich to 2050 consistent with the Climate Change Act 2008, supported by a strategy and policies in line with the carbon budget trajectory.
- A lower housing number (42,568 dwellings plus a 5% buffer) resulting in lower development pressures on greenfield sites;
- Growth concentrated in high density low car developments close to sustainable transport hubs, with a high concentration of growth located around Norwich.
- No dispersal of development to small villages which lack services.
- No new garden city settlements in open countryside distant from railheads (Thorpe Honingham, Hethel and Silfield).
- Protection of Green Wedges around Norwich.
- Development build to zero carbon standards that include renewable heating based on renewable energy generation
- Retrofitting of historic development.
- A transport strategy based on traffic reduction and a high degree of modal shift to bus, walking and cycling.
- Abandonment of a Norwich Western Link.
- No further major increase in road capacity.
For full representation see attachment.