Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 22717

Received: 12/03/2020

Respondent: Mrs Janet Hill

Representation Summary:

Question 7.
As mentioned in question 6 - there is a fundamental need to support the unsubstantiated statements in the vision and objectives with well reasoned, balanced and peer reviewed empirical evidence

Full text:

Question 6.
The projected vision is based on the premise that growth will deliver all sorts of wonderful good things - enhance the environment, the economy and peoples lives. The problem with this is that the received experience of all development in all parts of Britain and certainly in Norfolk since at least the 1970s is that it does not do this. Development brings more pollution, traffic, worsened services, more environmental damage, loss of countryside and lower quality lives. Unless the statements made can be proved by empirical evidence they are nothing more than mis-selling advertising, and should not be included in any statement related to the policies being suggested. It is important that the public should not be mislead and the statement clearly does so at present based on the past experience of 40 years of 'growth policy'.

Summary
The vision is misleading and does not represent the impacts of the proposed growth realistically or in a balanced way.
The vision is contrary to received experience of the impacts of development and therefore should be removed

Question 7.
As mentioned in question 6 - there is a fundamental need to support the unsubstantiated statements in the vision and objectives with well reasoned, balanced and peer reviewed empirical evidence

Question 11.
The delivery of housing and employment growth is predicated on the provision of 'sustainable' infrastructure - as stated in the Delivery Statement.
However, experience of the past 20 years has shown that the GNDP have totally failed to provide for the ability of infrastructure and services to keep pace with the projected and actual growth. Traffic numbers and congestion is increasing massively, public transport is failing to offer viable alternatives, air pollution issues are increasing, water demand is placing massive and unsustainable pressures on ground and surface water provision (low flows in rivers/ drying wetlands), and the services associated with our society (health, education, social services, older persons needs, younger persons services) are all failing. The prescription of more development will not solve this as it is excessive population growth that underlies the unsustainable stresses that have been placed on our society, environment and lives. The statement on infrastructure should reference that past performance has failed to deliver sustainable infrastructure and that the policies being promoted are based on 'more of the same' so that a 'health warning' on the ability of the GNDP policies to deliver sustainable and good infrastructure to support and improve lives, the environment and society is at best 'an intent', but with very little likelihood of success, and that the probable effect will be continuing decline in all measurable areas of infrastructure delivery as a result of policies proposed. This needs to be clearly stated in the proposed development plan
Summary
Experience of the past 20 years suggests that in all respects, infrastructure has failed to be delivered appropriately by the GNDP to support the existing growth in population. More of the same is unlikely to achieve the aims and statement set out in the document, and therefore this needs to be changed to reflect the past performance (failures) and a realistic and justified expectation of future performance in years ahead based on probable continuing decline in all areas of infrastructure delivery. To do otherwise is to mis lead the public
The fundamental problem that this plan has is that it is suggesting that the 'more of the same' mass development and large scale migration into the County, is in some way 'sustainable'. The experience of the previous 30+ years of significant development in and around Norwich has proved to be exactly the opposite -that it is NOT sustainable. The impacts on traffic numbers, air pollution, water resources, loss of countryside and open space, damage to biodiversity, extreme and dangerous pressure on the health services and social services - all of which are now in crisis - emphasises that this policy of 'growth' has not worked. Sustainability is the golden thread that runs through the planning system and is emphasised in the NPPF - to fail this test is to fail to justify the proposals and they should not proceed. - Clearly by any reading of the term sustainability, the current model and policies have failed, and the proposals in this new plan which continue on the same route, must therefore be deemed to fail the basic test of sustainability.

Question 14.

The statements throughout the document indicate time and again that the new proposed development will somehow bring improvements to peoples lives, their environment and their social and employment welfare. However, there does not appear to be any evidential justification for any such statements. Without any empirical evidence to support such statements, and in the light of past experience, to state that 'more of the same' will actually bring different results is clearly misleading and wrong. All such statements and allusions should be struck from the plan and in their place, it needs a clear indication of the effects and results of the development of the past 30 years -not dressed up and partially chosen bits of statistics that cover up the real truth of what people know to have happened in their county and to their lives, but an independently undertaken review of all the above areas of the functioning of the GNDP area (by at least two teams of independent academics from universities not in the region - who will allow peer review and accountability to their reports) this will then provide the basis for a new plan and a new set of objectives with information to allow reasoned judgement.

In the meantime, the proposals in the report to continue to add further development to the GNDP area should be halted as it is clearly unsustainable to propose more development when the existing development has failed to produce a sustainable, good society, economy and environment. There is already a vast amount of consented development potential which has yet to be realised in the current Plans - and which will no doubt continue to contribute to the decline in the quality of life of the County. There is therefore NO justification for more until proven evidence is available and presented to the Public in a manner which is not partisan and biased, and which will allow real assessment of the true effects of such development to be understood balanced against any benefits.

Summary
The evidence of the past 30 years of a growth strategy similar to that which is being proposed, has been unsustainable in terms of its adverse impacts on the environment (traffic density, air pollution, water resource impacts, loss of countryside, damage to biodiversity), society (increased crime, reduced social cohesion, failing schools, failing health services, failing social services) and the lowering in the quality of life for residents resulting from this and other related factors. More of the same is therefore unsustainable and fails the NPPF test in relation to suitable development. The plan should be completely re-thought
It cannot even be stated that 'growth' has brought about real increases in peoples incomes - with income levels for the median and lower incomes (the vast majority) lower in real terms than 10 years ago.