MM10 - Policy 4

Thank you for your consultation inviting comments on the Further Proposed Main Modifications and Additional Work (dated October 2023) produced by the Greater Norwich authorities.

National Highways' is responsible for the operation, maintenance and improvement of the Strategic Road Network(SRN) in England on behalf of the Secretary of the State. In the area within and surrounding Greater Norwich, we have responsibility for the A47 and A11. National Highways' is a key delivery partner for sustainable development promoted through the plan-led system, and as a statutory consultee we have a duty to cooperate with local authorities to support the preparation and implementation of development plan documents.

Following a review of the suggested changes, National Highways' considers the proposed Main Modifications are unlikely to have a significant impact on the SRN, and consequently we offer no further comment at this stage. National Highways' wishes to continue to be involved through the production of the Local Plan, in particular to issues and proposed allocation sites relating to Transport issues and the Strategic Road Network in the area.

Norfolk Constabulary support MM10 as a result of the inclusion of the wording 'Police Infrastructure' in Policy 4.

In relation to green infrastructure under the Other Strategic Infrastructure heading in Policy 4 Natural England previously submitted comments at Reg 19 stage in March 2021 which remain relevant here. These are attached, again, as we suggest the wording of this part of the Policy should be amended as suggested in section 6 (page 7) of the attachment in order to make the Plan sound.

The ICS Estates Team has been in discussions over the master-planning of the East Norwich Regeneration Area and the potential for a new build health facility and is working with Norwich City Council on a Supplementary Planning Document. For the benefit of making sure the adopted GNLP is fully up to date, it would be helpful to include this as an additional row to the Health Care Requirements table in Appendix 1: Infrastructure Requirements. The ICS Estates Team have also taken the opportunity to update the Healthcare narrative and appendix 1 table further to include projects in the Greater Norwich area, the table has been modified to show the projects required in each settlement area and their current status.

See attached full submission.

(Amendments to Appendix 1 are Additional Modifications so have no MM number. Appendix 1 is linked to Policy 4 so comments have been recorded under MM10)

Representations received from the Norwich Green Party (13 city councillors and four County councillors and four Broadland councillors.

Overall, we are disappointed to see the extent that the Plan would result in loss of green field land and vegetation to development, further suburbanisation of the rural landscape and sprawl around Norwich, more journeys by car in rural areas and in and around the suburban fringes of Norwich and a significant annual increase in carbon emissions from new dwellings alone.

See full submission attached.

Representations in relation to MM8, MM10 and Annexe 1
See attached full submissions for detail.

Greater Norwich Local Plan: Main Modifications Consultation

Please find comments from Norfolk Wildlife Trust regarding the main modifications on the Greater Norwich Local Plan below.

Policy 1: The Sustainable Growth Strategy
We welcome the inclusion of the new paragraph 187 which recognises that at present, there is no need to pursue the development of a new settlement.

On map 7 it states there are 1,919 houses from windfall, whereas table 6 gives a windfall allowance of 830.
We ask for clarification on which windfall figure is correct, in order to ensure that there aren’t any outstanding errors in the collective/overall (sites & windfall) allocation numbers.

Policy 2: Sustainable Communities
Point 1: We support the inclusion of reference to non-car modes and the encouragement of walking, cycling and public transport in relation to ensuring access to developments.

Point 3: We support the inclusion of street trees and other tree planting.

Point 4: We support the inclusion of the following sentence: “In the most accessible locations in Norwich, regard should be given to providing low or car-free housing in accordance with Policy DM32 of the Norwich Development Management Policies Local Plan”, but recommend that in order to ensure delivery of this policy in planning decisions that a more objective goal is set in the policy requirements, such as ‘In the most accessible locations in Norwich, low or car-free housing should be delivered in accordance with Policy DM32 of the Norwich Development Management Policies Local Plan’.

Point 7: We support the inclusion of this new sentence.

Point 8: We support this inclusion of this new wording around flood risk and water efficiency.

Point 9: We are disappointed that the final sentence “If the potential to set more demanding standards locally is established by the Government, the highest potential standard will be applied in Greater Norwich” has been removed and recommend that this be re-inserted.

Point 10: We object to the revision of this paragraph. Promoting the use of established assessment frameworks can be a resource-efficient way of delivering better quality and higher standards in new developments. There is an urgent need to build genuinely net-zero buildings as soon as possible. A significant role therefore remains for local planning authorities in setting binding netzero policies that are more ambitious than the Building Regulations.

Policy 3: Environmental Protection and Enhancement
The Natural Environment - “Development proposals [will be required to conserve and (deleted text)] should (added text) enhance the natural environment” We recommend that this be changed to ‘Development proposals will be required to enhance the natural environment, through the following measures, where applicable’ in order to restore the certainty of delivery in the previous wording whilst reflecting the updated focus on nature’s restoration in current national policy.

We note that the wording in the paragraph about biodiversity net gain has been amended: “[It will need to (deleted text)] should (added text) be demonstrated”. We recommend that this be changed back to ‘It will need to be demonstrated’ in order to restore the certainty of delivery in the previous wording whilst reflecting the updated focus on nature’s restoration in current national policy.

We welcome the inclusion of the reference to provision or enhancement of green infrastructure.
We support the inclusion of the new paragraphs regarding the requirement for a Habitats Regulations Assessment on proposals that may adversely affect European sites and the statement that applications will be refused if it cannot be ascertained that there will be no adverse impact.

Policy 4 Strategic Infrastructure
Transport
We are disappointed to see the inclusion of reference in the GNLP for the proposed Norwich Western Link (NWL) development by Norfolk County Council as a regional connectivity project. At a previous consultation stage for the GNLP we received confirmation that the NWL is not necessary for the delivery of any of the allocations in the plan and recommend that the policy wording here is revised to make it clear that there is no direct policy support in the GNLP for this controversial proposal, which we understand is due to be submitted as a planning application in 2024.

Due to the national importance for bat conservation of the woodlands and surrounding landscape on the proposed NWL route (and compliance with the multiple wildlife laws protecting bat roosts from disturbance, damage and destruction), we do not consider that it is possible that the NWL can be delivered, and consider that the need and deliverability of the proposal should not be taken for granted and given any policy weight in the GNLP. We therefore strongly recommend that the wording of the regional connectivity section of this policy is revised to only reference elements which have demonstrated they are necessary for the delivery of the GNLP.

Policy 6 The Economy
Point 2: We note the new paragraph “Support for rural enterprises through the conversion of rural buildings, the development and diversification of agricultural and other land based rural businesses and well-designed new build. If new build development is proposed to meet local business and community needs in rural areas the use of previously developed land and sites that are physically well-related to existing settlements should be encouraged where suitable opportunities exist. For sites beyond existing settlements and in locations not well served by public transport then development should be well designed and sensitive to its surroundings, should not have an unacceptable impact on local roads and should exploit any opportunities to make the location more sustainable.” We recommend the addition of wording that any new development should not have an unacceptable impact on the environment.

Policy 7.1 The Norwich Urban Area including the fringe parishes
Point 5 The Built, Natural and Historic Environment: The wording of the final bullet point for this section has been weakened by changing the wording ‘assist in delivering’ to ‘have regard to’ the River Wensum Strategy. We recommend that the original wording be used.

East Norwich: We note that the new text removes mention of corridors and enhancing linkages, as well as removing the mention of local energy networks. We recommend that these be re-inserted.

Policy 7.6 New Settlements
We support the deletion of this policy for new settlements.

Sites
General comment: We support the change of wording in site specific policies to strengthen the protection of trees (eg Point 3 and paragraph 2.140). We recommend updated policy wording to be applied consistently across all other site allocation policies where applicable.

Norwich Policy GNLP0360/ 3053/R10 East Norwich Strategic Regeneration Area (ENSRA)
Point 13a: states that “Development must allow scope for greater use of the Rivers Wensum and Yare for water based recreation, leisure and tourism including the potential inclusion of marinas and riverside moorings”. We recommend that additional text is added to stipulate that this would not have an adverse impact on the nature conservation value of these rivers.

We support the addition of text outlining the need for new developments for all sites within ENSRA to include high-quality pedestrian and cycle routes.

Monitoring Framework

Table 3 Sustainability Appraisal Indicators
We suggest including “rates of active travel (walking and cycling)” as an indicator within the air theme, with a target to ‘increase’. This will demonstrate policy effectiveness of policy 2 ‘sustainable communities.

We recommend that the percentage loss of the ecological network indicator within the biodiversity, flora and fauna theme needs revision, as it has no metric to measure it by at present. We suggest that this monitoring target covers the extent of priority habitats (as measured on MAGIC mapping) as an interim metric. This can be revisited this once the Nature Recovery Network map is completed.

We recommend the inclusion of an indicator reflecting population number of protected species within the biodiversity, flora and fauna theme, with a target of increasing population sizes.

I am writing with my comments on the proposed growth plans for the GNLP area.

These are copied to the Norfolk group of MPs as the matters raised touch upon urgent national policy in respect of planning, devolution, delivering on levelling up, housing and sustainable growth, and to the relevant ministers.

The locus for my comments lies in my previous involvement in engagement on the previous Greater Norwich Area Joint Core Strategy and the first GNLP plan; with the Norwich and Norfolk Growth agenda as a founding member of the New Anglia LEP’s Building Growth group; board membership of UEA’s ADAPT group; and through work on a landowner-led promotion of coordinated sustainable growth plans for the wider NE Norwich growth triangle (which were regrettably ignored).

I have further been a Commissioner on the Government’s Building Better, Building Beautiful Commission where I led the foundational property market research that underpinned the Commission finding identifying the ‘stewardship’ approach to land, infrastructure and property development / investment as being key to securing best outcomes and social value. I co-founded the Stewardship Initiative (see: www.stewardship-initiative.com with Knight Frank and The King’s Foundation to advocate for changes to support stewardship-led delivery. In July 2021 I was appointed to lead the start up and establishment of a municipal stewardship entity for Bournemouth Christchurch & Poole council as a ‘municipal stewardship’ entity. The remit was to unlock place-making led growth and levelling up, optimising development outcomes across 14 local authority owned sites. In this role I built a cross- disciplinary expert team which has improved the anticipated land use yield across the sites from circa 3500 homes to around 4500 homes plus a significant mixed use component, and attracting the interest of Homes England and institutional investors.

I attach previous comments made to the GNLP in respect of its initial plan. It is disappointing that the fundamental issues highlighted were not addressed and the short comings of development outcomes that were anticipated at that point have come through in the depressingly low quality of development that has subsequently taken place. The lack of robust consideration of sustainability(economic and environmental) and overall lack of place-making ambition that has been delivered across most volume development sites in Norfolk over the last 10 years is very disappointing.

I do not make these comments lightly. I have spent considerable energy through my work on the BBBBC (and other public and voluntary commitments referenced above) trying to get to the bottom of what conditions need to be put in place to secure improved growth outcomes. There are an increasing set of projects and approaches around the U.K. and internationally that demonstrate this thinking in action.

The GNLP plan in its current form will unfortunately not deliver on good growth. Equally concerningly, the suburbanisation of Norfolk that will be the inevitable outcome of the current approach ( and that of Breckland and North Norfolk) will undermine critical assets of the county which are implicit in its natural environment and present relatively unspoilt rural attractiveness which supports the county’s critical tourism and agricultural industries; attracts students and incomers, and supports a wealth of entrepreneurial businesses.

I have had the direct experience of gaining the initial interest of U.K. and overseas- based long term investors who have - at first sight - been attracted to the location and growth potential of the greater Norwich area. Having then seen the opportunity first hand, these interests have been taken aback at the lack of infrastructure and overall coordinated place-making that has been applied to what has been built out to date on the Norwich Fringe.

Equally, when taking part in discussions on the Cambridge growth proposition - which in contrast has been based on coordinated forward planning for delivery- there is no debate about the potential of the potential benefit if linkage with Norwich via the established ‘varsity corridor’. This is a lost opportunity both for Cambridge and for Norwich.

These points highlight the short-coming of the present approach to growth.

The points I would like to make are as follows:

1 Scope of Growth Plan

It makes very little sense for the plan to be limited to the GNLP area. Economic catchment and drivers need to be considered at the County level of scale with especial consideration given to the relationship with Cambridge as a key economic driver, however which is cannot accommodate demand (commercial and residential) at affordable levels.

At the County level of scale the role of the greater City of Norwich could further be considered alongside that of the respective large towns, Kings Lynn, Great Yarmouth and Theford which need proactive regeneration strategies and consideration of infrastructure requirements to support levelling up, and which have a strong role to play in supporting their respective hinterlands to underpin sustainable growth.

A county plan could also consider the interrelationship between the City / large towns and the network of small towns/ large villages with consideration being given to how these could become more self sufficient in economic, servicing and cultural terms to support a sustainable growth model.

A set of growth options might then be option and impact tested to consider how the high level of growth that is anticipated for the county might be executed in a genuinely sustainable way and made acceptable locally, given locally identified priorities and values, whether through urban intensification / brownfield ; the delivery of genuinely sustainable urban extensions; new settlement and / or dispersed village expansion. Critically the infrastructure requirement of respective options should be identified and costed in from the outset.

Essentially, at the county level of scale, water availability and catchment can be considered as a foundational element of growth planning and land use allocation; and a sustainable and funded approach to water should be built-in to growth plans. The same applies to consideration of sustainable energy and waste management, water neutrality ; biodiversity and landscape net gain.

The coordination of sustainable movement infrastructure and economic potential can also be properly considered at this level of scale to support trip reduction where possible and the adoption of sustainable modes.

This scale of planning and coordination is essential to the future regeneration and delivery of good growth.

2 Infrastructure Funding

A key finding of the LEP Building Growth group was that the need for up front infrastructure investment was the key barrier to delivering on the ‘over- hang’ of already permissioned sites.

Inherent in the stewardship proposition is the securing of investment for infrastructure to be paid for over a long term horizon, alongside and in complement to shorter term property investment and development funding to deliver housing and mixed uses.

Investment from public sources in addressing site abnormals and ensuring the delivery of community assets needs to be coordinated into an overall public / private investment package if high quality urbanism and well-infrastructured place making is to emerge.

Through embracing a regionally coordinated vision for growth it is very much more likely that the required long term investment can be secured.

This obviously links to a potential devolution settlement.

The County Council is well placed to raised requisite publicly sourced funds through channelling grant and PWLB sources to partner with the private sector whether infrastructure or real estate finance sources to unlock sustainable growth.

3. Delivery Capacity.

At county level, governance arrangements are already in place both to oversee planning for infrastructure and to oversee development and management of the natural environment. This could be extended further to oversee ‘good growth’.

In particular, there is potential for the County to undertake land use planning at this strategic level of scale.

Further, the county could be well placed to act in a commissioning capacity to an arm’s length delivery entity to operate as interface between the public and private sectors to secure best public outcomes.

The Repton Development company is already established. for example, and its scope could be revised to embrace a broader delivery role. Equally, there are models for strategic delivery entities that could be adopted, which have been well tested elsewhere, including Cambridge Horizons, Edinburgh Development & Investment.

4. Proactive Local Engagement.

In the past a number of us set up the ‘How Should Norfolk Grow?’ Initiative which Richard Bacon MP championed; and the CPRE and UEA were further closely involved with identifying a set of locally derived values that should underpin a locally appropriate growth proposition that, if embedded , would respect the county’s inherent assets. Any growth proposition should further research this area and adopt relevant, best-in-class characteristics of good growth that has been tried and tested elsewhere.

A new initiative should be established to engage widely; to deeply research attitudes and the asset base of the county; as well as considering relevant national and international comparators to inform placemaking and support a revised county level growth plan for locally acceptable, aspirational, sustainable growth.

5. Deploying available intelligent spatial modelling / impact testing

UEA has been in the vanguard of the application of advanced GIS, working with DEFRA to support land use planning within the natural environment. This should be built upon - potentially working with a parallel initiative that has been established in Cambridge and with the Geo-Spatial Commission - to use intelligent spatial modelling to support option and impact testing of spatial and land use options to support strategic decision making.

Such a resource, once established can go on to support planning and infrastructure decision making at all levels of scale. This could further become a specialism and centre of excellence that could be exported.

I would be pleased to have the chance of a dialogue with the GNLP board on these points. None of this is ‘innovative’ or untested.

These ideas have a foundation in approaches that have underpinned the successful delivery of - for example - of the Cambridge growth phenomenon.

The County is at a turning point. We have the chance to aspire to secure a sustainable future for Norfolk, building on its assets and character or we can continue to suburbanise and destroy the essential quality of place. The latter approach would be a tragedy.