Draft Greater Norwich Local Plan – Part 1 The Strategy

Object

Representation ID: 23105

Received: 31/03/2020

Respondent: Salhouse Parish Council

We supported the continuation of the settlement hierarchy as defined in the JCS. We wonder why and where the concept of “village clusters” has been introduced into the planning process.
For many reasons they appear to be a flawed unsustainable concept. A real strength of the JCS was its inclusion of a Norwich Policy Area and Rural Policy Areas, and therefore we are very disappointed that this distinction has been abolished. The Rural Policy Areas gave real protection to the countryside: this is threatened by the introduction of the village cluster approach. This is another example of how the Draft GNLP contradicts the existing agreed Local Plan.
As noted above in our response to Q1 CPRE Norfolk has serious misgivings about the separation of the sites and allocations for new housing in the South Norfolk Village Clusters from the rest of the GNLP and its current consultation. In addition, we strongly object to the use of the open-ended statement that these South Norfolk “village clusters” will be allocated a ‘minimum’ of 1,200 houses, rather than giving a maximum number as is the case for the Broadland “village clusters”. If the reason for this separation is, as was given at the recent GNDP meeting of 6th January 2020, the lack of suitable sites coming forward in these South Norfolk “village clusters”, then this gives another good reason why the delivery of housing should be phased. Clearly the sites included in the JCS have undergone rigorous assessment and their inclusion in the Local Plan is an acknowledgement of their suitability for development. It makes absolute sense that these suitable sites should be developed first especially given the fact that any new sites coming forward are deemed to be unsuitable.
Paragraph 163d states that the strategy for location of growth ‘focusses reasonable levels of growth in the main towns, key service centres and village clusters to support a vibrant rural economy’, before suggesting that the approach to “village clusters” is ‘innovative’. The claim that providing new housing in such locations will support services is, we contend, largely illusory. Instead, additional new housing will lead to more car and delivery vehicle journeys, with residents travelling longer journeys to access the services they require such as health services and a supermarket. Given that the majority of any such new houses will be larger “family” homes, with children just or more likely to be of secondary or tertiary school or college age than of primary school age. This will have further impacts on carbon reduction due to the additional journeys needed to secondary schools or colleges.
It is clearly demonstrated in the table on page 80 of the 23 June 2017 GNDP Board Papers that the most reasonable option for the distribution of housing in terms of the environment (e.g. 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; promoting the efficient use of land; respecting the variety of landscape types in the area; ensuring that everyone has good quality housing of the right size; maintaining and improving the
quality of life; reducing deprivation; promoting access to health facilities and healthy lifestyles; reducing crime and the fear of crime; promoting access to education and skills; 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; conserving and enhancing the historic environment and heritage assets; minimising waste generation; promoting recycling; minimising the use of the best agricultural land; maintaining and enhancing water quality and its efficient use) is Option 1: urban concentration close to Norwich. In terms of all these factors taken together the least desirable option as shown on this chart is Option 4: dispersal. We therefore strongly support urban concentration in and close to Norwich as the way forward, because it is best for the environment, minimising climate change and the well-being of residents.
There is very little economic evidence to suggest that cementing new housing estates on the edges of villages will bring any boost to local services, but rather they will put a strain on these services, where they exist.
We cannot understand why the table showing the same set of factors in the Interim Sustainability Appraisal for the GNLP 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.
Given the clear benefits and advantages from these documents for the environment, climate change and other areas, as well as other reservations around lack of sustainability and issues of delivery, we strongly urge the GNDP to remove the requirement for additional new sites for housing in the “village clusters” from the GNLP.
The strategic economic growth is concentrated to the SW of Norwich, while the biggest housing growth is to the NE?

Object

Representation ID: 23106

Received: 31/03/2020

Respondent: Salhouse Parish Council

Paragraph 145 claims that the strategy ‘is informed by consultation feedback’, yet chooses to ignore much from previous consultations even where such feedback was significantly in favour of a particular approach. An example of this is the position taken towards windfalls. Responses to the Stage A Regulation 18 Site Proposals and Growth Options consultation were significantly against (110 to 45) counting windfalls in addition to the additional (at that point 7,200) housing, and yet this has been ignored in the current draft plan consultation. By not counting windfalls in the calculation for housing numbers in table 6, there will be a resulting over-supply of houses, particularly if the out-of-date 2014 National Housing Projections are used. Windfalls are acknowledged as a reliable source of new housing and many Local Authorities do count them towards their housing targets: their contribution towards housing targets in the GNLP should lead to a reduction in the number of new sites which are allocated.
CPRE Norfolk also has specific concerns about the approach for housing numbers in the South Norfolk Village Clusters, as there is no total figure given for this new housing, but instead an open-ended ‘minimum of 1,200 homes’. This use of the word “minimum” needs to be removed and replaced by a “maximum” total, so that further potential over-supply is avoided. At best, the actual delivery of new housing in the plan area has just exceeded 2,000 dwellings per annum, with 1,500 being more typical. At this build-rate, current commitments cover actual housing need to 2038.
CPRE Norfolk wants to see sites allocated for housing in the existing plan (JCS) developed before any new sites that are likely to be added in to the emerging GNLP are built out. Although we understand that it will not be possible to prevent new sites being included in the plan, we are asking that these extra land allocations for housing are treated as phased development and that building should not occur on these sites until the current JCS sites have been used up. We think this is a sensible approach because not only does it protect the countryside, but also at current rates of house building there is enough land already allocated in the JCS to cater for the building that is likely to occur over the new Plan period.
There is very little evidence to show that increasing the amount of land on which houses can be built actually increases the rate at which they are built. All that happens is that developers ‘cherry-pick’ the most profitable sites, which are likely to be the newly
allocated green field sites and that this will lead to even more land banking of currently allocated sites. This will also mean that many less sustainable (or as CPRE Norfolk would argue, unsustainable) sites for housing are developed rather than those with more sustainable locations. This would result in more pollution and congestion, with the negative consequences for the climate and climate change. It also means that expensive infrastructure which has been provided to facilitate new housing in the existing plan, could end up being an irrelevant and embarrassing white elephant.
It is disappointing that there is no mention of phasing as an option within the consultation document, as this would help to prevent the worst excesses of unnecessary development. 69 Parish and Town Councils in Broadland and South Norfolk (over 38%)have supported CPRE Norfolk on this issue and have signed a pledge to this effect, which was included in the previous consultation, but ignored in the current draft Plan. With this groundswell of grassroots opinion making such a strong case, we urge the GNDP in producing the GNLP to consider phasing seriously as the most reasonable way forward. Clearly there is a democratic deficit: meaningful consultation should not ignore this volume of common-sense opinion.

Comment

Representation ID: 23107

Received: 31/03/2020

Respondent: Salhouse Parish Council

No definition of a ‘Green infrastructure priority corridor’ or how this would work??

Comment

Representation ID: 23108

Received: 31/03/2020

Respondent: Salhouse Parish Council

Commenting on Policy 2 – Sustainable Communities, CPRE Norfolk questions the use of the words “as appropriate” in the policy’s introduction, as this means the requirements would be far too open to interpretation as to what is “appropriate” and therefore opportunities to ensure that ‘mitigating and adapting to climate change, [and] assisting in meeting national greenhouse gas emissions targets’ will be missed.
This concern is particularly relevant when considering how new housing development in the “village clusters” will fulfil the first
requirement to ‘ensure safe, convenient and sustainable access to on-site and local services and facilities including schools, health care, shops, leisure/community/faith facilities and libraries.’ The rationale behind these “village clusters” appears to be mainly based on the availability and accessibility of a primary school. However, safe, convenient and sustainable access to the other features on this list are equally important. Adequate health care and shops simply are not available in these ways to many of the preferred new sites for housing in the “village clusters”, therefore giving further reasons why such sites should not be included in the GNLP.
There is a worrying disconnect between the aspirations in point 6 with the need to ‘manage travel demand and promote public transport and active travel within a clearly legible public realm’, and the imposition of additional new housing in “village clusters”. It is difficult if not impossible to see how residents of the majority of this new housing will be able to use active travel or public transport, due to the likely distances from workplaces and the lack of suitable public transport.
If additional new housing is developed in “village clusters” most of the working residents will not have ‘good access to services and local job opportunities’. Instead there will be an unsustainable increase in the number of journeys to and from work using private vehicles, which will not be electric-powered certainly for the majority of the plan period. It is very doubtful if additional housed will provide enough business to keep a village shop open, but they will definitely increase the number of journeys made for delivery and service vehicles, making this housing even more unsustainable.
If communities are to ‘minimise pollution’ as required to do so by point 8, it is imperative that no additional new housing is allocated to “village clusters”, as this would lead to an increase in petrol and diesel-powered vehicle journeys to and from such housing. This, along with the resultant increase in congestion, makes this additional housing highly undesirable.

Comment

Representation ID: 23109

Received: 31/03/2020

Respondent: Salhouse Parish Council

We comment on various aspects of Table 8 relating to Policy 2.
Point 3, Green Infrastructure. The opening statement is: ‘Developments are required to provide on-site green infrastructure appropriate to their scale and location’. The three main benefits listed are biodiversity gain, promotion of active travel and the reduction of flood risk, which are key NPPF priorities.
The NPPF is also supportive of biodiversity on a more strategic scale, and the importance of ecological networks and Nature Recovery Networks. While Green Infrastructure is useful, and can play a role in these, it clearly has limitations in a wider role across the wider countryside, and in linking high designated nature conservation sites.
Point 5, Landscape, should recognise that valued landscapes often sit with good wildlife habitats. This is particularly the case for river valleys and the Broads. A strong message from the Environment Plan and the recommendations from the recent Landscapes Review is to make links between landscapes and wildlife, and not consider them in isolation. This is covered more fully in our response to Q21.
Point 9, Water. In our view it needs to be recognised that SUDS is not a silver bullet when dealing with flood risk. Areas of low-lying land with a high water-table can present a problem in ‘getting the water way’, and if it does manage to do that existing settlements can be put at risk.
A high level of growth puts a greater pressure on the capacity of Waste Water Treatment Works, both on the discharge of effluent into river systems, and on flood risk with foul water. This will be exacerbated by under or lagging investment in WWTW. Although not the responsibility of the Greater Norwich Authorities, their Annual Monitoring Reports (AMRs) should record and monitor incidents.
The statement in Point 9, Water - Key issues addressed by policy 2 states that: ‘Government policy expects local planning authorities to adopt proactive strategies to adapt to climate change, taking into account water supply and demand considerations. It allows local plans to set a higher standard of water efficiency than the Building Regulations where evidence justifies it. For housing development, only the higher Building Regulations standard for water prescribed by Government (110 litres per person per day) can [be] applied through local plans and more demanding standards cannot be set. If the potential to set more demanding standards locally is established by the Government in the future, these will be applied in Greater Norwich.’ The closing note at the bottom of the wording states: ‘Implementation of the standards for water efficiency will be supported by an updated advice note.’
We comment that it is imperative that Per Capita Consumption (PCC) of water is further reduced below the Government's prescribed 110 litres per person per day in order to deliver the statement made in Section 3, paragraph 129 which states: ‘Greater efficiency in water and energy usage will have minimised the need for new infrastructure, and further reductions in carbon emissions will be delivered through the increased use of
sustainable local energy sources. New water efficient buildings will have also contributed to the protection of our water resources and water quality, helping to ensure the protection of our rivers, the Broads and our other wetland habitats.’ East Anglia is the driest region of the UK, our aquifers, rivers and wetlands are already at breaking point, as are many of the regions farmers who are seeing their abstraction licences reduced or revoked. If more demanding standards to reduce PPC water consumption are not set as part of the local plan, this will further adversely impact upon the environment, impacting upon the Broads and wetlands, which in turn will impact the regions aspirational growth for tourism and will severely impact the regional agricultural economy.
These pressures are further evidence as to why the amount of new housing should be tightly controlled.

Comment

Representation ID: 23110

Received: 31/03/2020

Respondent: Salhouse Parish Council

CPRE Norfolk supports further ‘development of a multi-functional green infrastructure network’. However, we have major concerns about how biodiversity net gain will be evaluated, assessed and measured, although it is recognised that at this point it is unclear as to what the legal requirements of this policy will be given the current progress of the Environment Bill.
Paragraphs 183 and 184 talk about the great weight placed on protecting the natural environment in Greater Norwich, but then there are no clear details on how this will be achieved. Provision of a Green Belt on a ‘green wedges’ model would go some way to addressing this.
This draft Plan takes a very narrow view on the NPPF and 25-Year Plan on policies for the natural environment, namely that strategy, aims and policies are restricted to considering only gain as seen through the prism of development. There is a duty to cooperate between Councils, and that should automatically happen. While implementation may be less direct, there should be a wider strategic vision that does support policies of the NNPF. CPRE Norfolk has a proposal for a Nature Recovery Network from the North Norfolk Coast to the east coast (including parts of the Broadland DC area), by the enhancement of the ecological network provided by our river systems, and supported by the environmental land management scheme. This includes a detailed planning and land management document for landscapes and wildlife relating to a Nature Recovery Network, which also include an AONB extension to the Norfolk Coast AONB into the full catchments of the twin North Norfolk rivers Glaven and Stiffkey.

Object

Representation ID: 23111

Received: 31/03/2020

Respondent: Salhouse Parish Council

Yes, the decision to remove a possible green belt for Norwich on the green wedges (or other) model from the draft Local Plan is, in the opinion of CPRE Norfolk, unjustified, particularly bearing in mind the large degree of support it received in the earlier Stage A Regulation 18 Site Proposals and Growth Options consultation.

Support

Representation ID: 23112

Received: 31/03/2020

Respondent: Salhouse Parish Council

CPRE Norfolk supports the provision of new railway stations at Rackheath and especially Dussindale as outlined in paragraph 206.
We note the contradiction in the Transport for Norwich Strategy as reflected in Policy 4 – Strategic Infrastructure, when it aims ‘to promote modal shift’ by having ‘significant improvements to the bus, cycling and walking network’ on the one hand, but promotes ‘delivery of the Norwich Western Link road’ on the other. CPRE Norfolk fully supports the former set of aims while opposing the latter.
CPRE Norfolk supports ‘protection of the function of strategic transport routes (corridors of movement)’, and as part of this strongly suggests that no industrial development should be permitted on unallocated sites along such corridors of movement.
The desire to support ‘the growth and regional significance of Norwich Airport for both leisure and business travel to destinations across the UK and beyond’ surely contradicts the aspirations for addressing climate change stated within Section 4 of the draft GNLP?
Public transport provision needs to be improved and made affordable, not only between main towns and key service centres, but to and from smaller settlements. This is essential even without any further growth of these settlements, as many areas of rural Norfolk have become public transport deserts.
Transport needs to be organised with the priority being ‘service’, with frequency and early/late running availability, and services provided according to need, not commercial viability. Subsidise if necessary.

Comment

Representation ID: 23113

Received: 31/03/2020

Respondent: Salhouse Parish Council

Priority needs to be given to improving inadequate infrastructure and developers should not be permitted to utilise existing infrastructure without consideration for its capacity.

Support

Representation ID: 23114

Received: 31/03/2020

Respondent: Salhouse Parish Council

CPRE Norfolk supports the affordable housing policy within Policy 5 – Homes. It is essential that the requirements of this policy are followed when progressing applications for housing on sites of 10 dwellings or more. Any policy which encourages the building of a greater proportion of affordable homes should be adopted. It is to be hoped that government policy will change further regarding viability tests so they become more transparent, so that it would be less easy for developers to evade their responsibilities to deliver affordable homes. More central government intervention is required if these needed homes are to be built. Ideally, affordable and social housing should be provided where needed as a stand-alone provision, and not be connected to private developers’ housing targets. Lessons must be learned from the history of poor delivery of affordable homes, to ensure that the policy to provide 28% or 33% affordable houses must be enforced. We support rural exception sites as a means of supplying needed local affordable and social housing. An approach based on the provision of stand-alone sites such as these, in our opinion is a far better method for addressing affordable and social housing needs.
Developers who win planning consent based on a certain percentage of affordable housing should be legally obliged to construct that percentage even if it leads them to a loss. They should not be permitted to claim ‘non-viability’. Their commercial proposal should be binding or they should relinquish the site.