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Publication
76
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.
Object
Publication
85
Representation ID: 24491
Received: 22/03/2021
Respondent: Norwich Green Party
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The local rail network around Norwich is limited compared to new rail infrastructure around Cambridge where Cambridge North station has been built to serve major growth close to the city and Cambridge South station is planned. Whilst the GNDP has devised the concept of a Norwich - Cambridge Arc, Norwich is the poor relation in terms of sustainable transport infrastructure.
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.
Object
Publication
89
Representation ID: 24492
Received: 22/03/2021
Respondent: Norwich Green Party
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
89. Transport for Norwich and the Transforming Cities Programme
Transport for Norwich and its predecessor, the Norwich Area Transportation Strategy Implementation Plan (NATS 2013), based around modal shift to bus, walking and cycling, have been successful in reducing vehicles entering the city centre and increasing the numbers of journeys on foot and by bike. Bus service improvements have also been achieved but the Councils are a very long way from delivering an upgraded bus infrastructure plan based on six corridors for the Norwich built up area as promised by the Joint Core Strategy. An application was made to the Transforming Cities Fund for between £74m to £127m for bus infrastructure schemes. Norfolk County Council was awarded £32m and currently, no other sources of funding have been identified.
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.
Object
Publication
93
Representation ID: 24493
Received: 22/03/2021
Respondent: Norwich Green Party
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
We agree that mitigating the effects of climate change within the Greater Norwich area should be a cornerstone of the GNLP.
Although the GNLP has been strengthened by a stated objective to reduce per capita emissions and contribute to meeting the national target to achieve net carbon zero by 2050, the strategy for growth and supporting policies are not in line with S19 (1A) of the Planning and Compulsory Purchase Act 2004.
In 2021, government will set the level of the sixth carbon budget, covering 2033 to 2037. This will require faster progress in reducing emissions as the UK emissions are currently projected to exceed the legally binding 4th and 5th carbon budgets for the years 2023 to 2027 and 2028 to 2032.
The Committee on Climate Change is advising that the UK set its sixth Carbon Budget to require a 63% reduction in emissions across all sectors including international aviation and shipping between 2019 and 2035 (a reduction in UK of emissions of 78% by 2035 relative to 1990).
The GNLP Plan period 2018 – 2038 will be a critical period for local councils to contribute to net zero greenhouse gas emissions by 2050 and hence the vitl importance of crafting and adopting a Local Plan which meets the challenge.
The Centre for Sustainable Energy, Dr Andrew Boswell and others address the planning framework for climate change and local plans. We would like to make the following observations about the lack of priority given to climate change during plan preparation.
The GNLP Regulation 18 Growth Options Consultation (early 2018) treated climate change as a subordinate matter. The Foreword, ‘The Choices We Face’ bracketed climate change along with other environment issues in the Draft Vision and Objectives viz:
“To protect and enhance the built and natural environment, make best use of natural resources, mitigate against and adapt to climate change”.
The GNDP’s Favoured Option on climate change was the ‘Current Policy Approach’ (ie that taken by the adopted Joint Core Strategy (2011)) based on minimising greenhouse gas emissions in new development, with no reference to addressing the contribution made by transport.
The GNLP Regulation 18 Consultation was deferred by 3 months to Jan 2020 to address various shortcomings raised by GNDP members that included the need for improved actions to address climate change. (GNDP Member Board Meeting Minutes 26 Sept 2019).
The GNLP Regulation 18 C (Consultation 29 Jan to 16 March 2020) was strengthened to reflect current thinking on climate change viz:
Environment Objective
“To protect and enhance the built, natural and historic environments, make best use of natural resources, and to significantly reduce emissions to ensure that Greater Norwich is adapted to climate change and plays a full part in meeting national commitments to achieve net zero greenhouse gas emissions by 2050.”
Nevertheless, the added reference to net zero was not reflected in the body of the Plan. At the GNDP Board on 6 Jan 2020, a member questioned whether measures in the Strategy for a low carbon future were sufficiently robust.
The GNDP Board agreed to carry out further work on housing needs and delivery issues, a viability study and CIL evidence and economic evidence, but notwithstanding some member concerns over climate change, no further work was agreed on this score.
Plans for further consultation were upended by the Planning White Paper in late July 2020 and the GNDP decided to take a Regulation 19 GNLP to consultation in early 2021.
Norfolk planning authorities will now pursue climate change work through the Norfolk Strategic Planning Framework Forum. A paper ‘Climate Change and the Planning System’ tabled at the forum on 25 January 2021
identified current opportunities for the planning system to support decarbonisation. Alongside, members agreed through the revised draft Norfolk Strategic Planning Framework to address climate change more fully through a policy review of the GNLP following its adoption.
Deferral would result in several years’ delay before a Local Plan that is better aligned with climate change policies is adopted. Meanwhile, the GNDP is relying on central government policy changes for carbon cuts.
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.
Object
Publication
94
Representation ID: 24494
Received: 22/03/2021
Respondent: Norwich Green Party
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Although nitrogen dioxide levels have been falling in the AQMA, breaches continue, notably on Castle Meadow, the main bus corridor.
Particulate matter pollution is an even more serious concern. Fine particulate matter (PM2.5) has been shown to affect every organ in the body. The WHO has set a limit for PM2.5 at 10mcg/m3 whilst recognising that there is no healthy limit. In Norwich, where road traffic is a major pollutant source, a study by Public Health England attributed 5.5% of deaths of people aged 25 and over in 2010 to PM2.5. Although PM2.5 levels have fallen slightly in Norwich, they remain above the WHO limit in the city and just below the WHO limit in suburban and rural parts of Greater Norwich. Electric cars would not avoid the friction of rubber tyres and brakes on road surfaces, a major source of PM2.5.
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.
Object
Publication
95
Representation ID: 24495
Received: 22/03/2021
Respondent: Norwich Green Party
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Locally per capita CO2 emissions have fallen, largely driven by the fall in emissions from the national power sector. Data on per capita emissions (from transport, domestic dwellings, commercial/industrial settings), collected by the Department of Business, Energy and Environmental Strategy excludes emissions from international aviation, shipping, production and consumption. Consequently, per capita emissions are higher than presented by officials figures and radical cuts will be required to achieve Net Carbon Zero.
At the present rate of carbon emissions, the Tyndall Centre for Climate Change Research using Scatter (a carbon footprint tool to reduce city-level emissions) estimates that Norwich will use up its global carbon budget within around seven years.
The City must cut its carbon emissions by 13% every year to meet its contribution to Net Zero. Broadland and South Norfolk with their higher emissions from road transport must make an annual cut of 13% and 14.25% respectively.
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.
Object
Publication
96
Representation ID: 24496
Received: 22/03/2021
Respondent: Norwich Green Party
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Information should be included on the implications of changes in temperature and precipitation. These include impacts on human, plant and animal health, with implications for food production, water supply, infrastructure, public health and education. The National Trust has mapped the various effects of climate change in England and Wales between 2020 and 2060 and shows major overheating across the whole of the south east and east of England by 2060.
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.
Object
Publication
98
Representation ID: 24497
Received: 22/03/2021
Respondent: Norwich Green Party
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Under this section, coastal flooding and sea level rise must be referred to. Whilst the GNLP area is not coastal, the extent of the 5 districts that lie within flood zones 2 and 3, the low lying nature of the coast to the east, the Broads area which extends into Norwich and rivers running through the area to the sea are significant risks. Additional carbon emissions from new significant growth in GNLP area plus delays in cuts to existing emissions would contribute to rising global temperatures leading to an increase sea level rise and stormier seas.
For further information, see section on Flooding on pages 28-31 of the Centre for Sustainable Energy paper which highlights advice from the Environment Agency on the need to plan for two scenarios for a cumulative sea level rise of 1.20m and 1.60m between 1990 and 2115.
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.
Object
Publication
99
Representation ID: 24498
Received: 22/03/2021
Respondent: Norwich Green Party
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Under this section, coastal flooding and sea level rise must be referred to. Whilst the GNLP area is not coastal, the extent of the 5 districts that lie within flood zones 2 and 3, the low lying nature of the coast to the east, the Broads area which extends into Norwich and rivers running through the area to the sea are significant risks. Additional carbon emissions from new significant growth in GNLP area plus delays in cuts to existing emissions would contribute to rising global temperatures leading to an increase sea level rise and stormier seas.
For further information, see section on Flooding on pages 28-31 of the Centre for Sustainable Energy paper which highlights advice from the Environment Agency on the need to plan for two scenarios for a cumulative sea level rise of 1.20m and 1.60m between 1990 and 2115.
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.
Object
Publication
100
Representation ID: 24499
Received: 22/03/2021
Respondent: Norwich Green Party
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Under this section, coastal flooding and sea level rise must be referred to. Whilst the GNLP area is not coastal, the extent of the 5 districts that lie within flood zones 2 and 3, the low lying nature of the coast to the east, the Broads area which extends into Norwich and rivers running through the area to the sea are significant risks. Additional carbon emissions from new significant growth in GNLP area plus delays in cuts to existing emissions would contribute to rising global temperatures leading to an increase sea level rise and stormier seas.
For further information, see section on Flooding on pages 28-31 of the Centre for Sustainable Energy paper which highlights advice from the Environment Agency on the need to plan for two scenarios for a cumulative sea level rise of 1.20m and 1.60m between 1990 and 2115.
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.
