Object

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 20562

Received: 07/03/2020

Respondent: Mrs Catherine Smith

Representation Summary:

The GNLP calculates housing needs based on the 2014 National Household Projection. It should use the 2016 National Household Projections and there is no acceptable excuse for not doing so.

Full text:

I make no apology for echoing other residents concerns as detailed below.

General objections:
The GNLP is deeply flawed. It appears to pursue a political agenda rather than duly considering sensible and pragmatic issues and flouts national policy on climate change mitigation.
The recent Court of Appeal decision to rule the expansion of Heathrow unlawful because it didn’t take climate change commitments into account puts the proposed GNLP in a dubious position, given that its proposed higher levels of rural development would lead to increases in carbon emissions, which contravenes national planning policy to facilitate their reduction. This would inevitably lead to it being challenged on that basis. It could even be that a legal challenge would be upheld and the policy deemed unlawful.
I’d argue that the GNLP is a redundant document, given that the current Joint Core Strategy has only been in effect since 2014 and covers the period up to 2026. Certainly, the unexplained change in policy in the GNLP concerning rural development is startling and inappropriate.
One of the core strategies in the JCS was to locate housing and other growth primarily in and close to Norwich, with minimal new development to be permitted in rural areas. One of the stated reasons for the development of the NDR, at great public expense, was to help the distribution of traffic to and from new housing built inside its length and in the northeast growth triangle (as that is what the JCS pointed to). The GNLP consultation document abandons that policy and sacrifices the important protection the JCS gave rural communities against inappropriate development. The main justification for this appears to be the availability of primary school places in the “village clusters”. The issue of climate change is a much more important factor and appears to have been completely ignored despite the introduction stating that ‘the GNLP must also assist the move to a post-carbon economy and protect and enhance our many environmental assets.’. This goal is completely undermined by the proposed policy.
The GNLP calculates housing needs based on the 2014 National Household Projection. It should use the 2016 National Household Projections and there is no acceptable excuse for not doing so.
Objections Specific to Reedham
Paragraph 120 of the GNLP stresses the need for good access to services and facilities, but the decision to allocate up to 60 new houses to the village appears to be based almost entirely on the fact that the primary school has a number of vacancies. This is poor decision-making,.
The recent development of 24 houses in Barn Owl Close in Reedham has resulted in one person of school age moving into the village. Clearly, the provision of additional housing does not automatically guarantee increased take-up of school places.
Other services in the village are extremely limited. There is a doctors’ surgery; it is only open four half-days per week. There is a post office; it is only open three half-days per week. There is no free cash point. There is a village store; most people use it for odds and ends and do most of their shopping at supermarkets in Acle (six miles each way), Yarmouth (10 miles each way) or Norwich (16 miles each way), to which they drive or from which they have their groceries delivered.
There are no significant employment opportunities in Reedham. The current businesses are generally fully staffed and do not have plans for expansion and it is not a village that will ever attract new business because of its location and lack of access to good roads.
Given the lack of employment opportunities within the village, there will be a massive increase of journeys from and to work for many of those living in any such new housing, as well as additional journeys by delivery vehicles.
Paragraph 125 states the need for ‘a radical shift away from the use of the private car, with many people walking, cycling or using clean public transport.’ That is not feasible for people who live in Reedham, where 96% of journeys are made by private car due to the infrequency or unreliability of public transport. This may not be an issue if we ever reach a point where electric-powered cars predominate, but it’s a huge gamble to base policy on that happening within the lifetime of the GNLP.
Another significant issue with the increased road traffic the proposed additional development would cause is that the road infrastructure in and around Reedham is poor and would not support the increased demand. The required road width for any road servicing 50 or more dwellings is 5.5 metres.
Most of the roads within Reedham do not comply with this requirement. Mill Rd is 3.8 metres wide, narrowing to 3.2 - 3.3 metres in places. Church Road is 3.7 metres at its narrowest point, and only 4.4 metres at its intersection with Freethorpe Rd. Station Road beyond Barn Owl Close is 4.2 metres wide. The Hills is 4.2 metres wide.
Site Specific Objections
GNLP1001
I object to GNLP1001:-
Outside the development boundary for the village.
Contrary to GNLP Policy 2 issue 1 as the site cannot provide “safe, convenient and sustainable access to on-site and local services and facilities including schools, healthcare, shops, leisure/community/faith facilities and libraries” without the use of a car.
Contrary to GNLP Policy 7.4 347 as there is no safe walking route to school. As per the Discussion of Submitted Sites “Sites which do not have a safe walking route to school, or where one cannot be created, will not be considered suitable for allocation”. Highways have confirmed it is not feasible to provide an off-carriageway pedestrian facility to enable safe journeys to school.
GNLP3003
I object to GNLP3003:-
Outside the development boundary for the village.
Contrary to GNLP Policy 7.4 347 as there is no safe walking route to school. The Discussion of Submitted Sites states “Sites which do not have a safe walking route to school, or where one cannot be created, will not be considered suitable for allocation”. Highways have confirmed it is not feasible to provide a footway to enable safe journeys to school as there is no scope for improvements within the highway.
The single entrance access is too narrow with no scope to widen. Highways confirm it is not feasible to provide a safe access as the carriageway is narrower than required for 2-way traffic and there is limited site frontage to the highway.
The HELAA Conclusion states that Mill Road is “relatively lightly trafficked”. However, there is no evidence to support this statement.