The purpose of the plan is considered to be clear; to deliver new housing in a sustainable way so as to meet the challenges of climate change, and the move to a post-carbon economy. However, we would raise concerns as to whether the proposed approach to the distribution of growth, the carrying forward of a substantial percentage of previously allocated sites (82%), and the approach to new allocations, appropriately support this purpose.
Climate change, and the move to a post-carbon economy will be key factors to guiding growth, and the proposed flexibility within the draft strategy is welcomed. However, in times of such rapid change, complex challenges and significant opportunities a change to the status quo is required. The proposed carrying forward of allocations and concentration of growth to existing urban areas is considered to be misaligned with the aspirations of the Greater Norwich Local Plan, particularly in the context of Norwich City Council having declared a climate emergency and pledging to be carbon neutral by 2030, and the national target of 2050. Such an approach is considered to fail to adequately adapt to the changing circumstances and priorities of the Greater Norwich area, and beyond.
As such we would raise concerns that the strategy for growth and associated allocations are not forward thinking enough to deliver truly sustainable, resilient and attractive communities.
We would also raise concern regarding the delivery of a significant proportion of proposed carried forward allocations, in light of their not being delivered within the previous plan period. These sites should be subject to appropriate scrutiny, and more detailed evidence required from landowners and developers in order to demonstrate the ability to deliver within the Plan period. Without such, the delivery of the Strategy is placed at risk through opportunistic largescale development which undermines place-making, sustainability and climate resilience.