Comment

Representation ID: 22426

Received: 16/03/2020

Respondent: Norwich Green Party

Ref. the interim sustainability appraisal which assesses policy options against the 15 sustainability objectives established by the scoping report. We are very concerned that the interim sustainability appraisal undermines its whole purpose by also considering ‘delivery’ as a factor to weigh against the objectives. This is summed up by p52 of the appraisal: after a table presenting the six options for distribution of housing allocations (p42), in which it is absolutely clear that options 1, 2 and 3 perform better than the dispersal options (4, 5 and 6), the “summary of significant effects” starts: “Options 1, 2 and 3 may be harder to deliver”, goes on to observe that 1,2 and 3 perform better on everything else, then concludes “in sustainability terms the choice between alternatives appears finely balanced, with no alternative clearly better than another in SA terms”.
This is dishonest. The only objective on which 4, 5 and 6 are deemed to perform better is SA5, “Ensure that everyone has good quality housing of the right size and tenure to meet their needs”. In the ‘analysis’ of this objective on p45, there is no mention of meeting need (which surely relates to providing affordable housing in places where there are jobs and where people therefore want to live); instead, this becomes “diversity, choice and competition in the market for land” and “least risk of delay”, and judges dispersal the best option – ignoring the fact that this will result in unaffordable housing in unsustainable non-communities with no employment, so not actually meeting need at all. SA5, therefore, is first twisted to have a completely different meaning in order to support dispersal, then considered to outweigh all the other objectives put together (there’s no hierarchy of objectives in the SA) to the extent that the dispersal options become equally sustainable to options that would concentrate growth where infrastructure and services are.
“Delivery” is not an objective in the Sustainability Assessment and should be disregarded for the purpose of weighing up policies on sustainability grounds.